CAMP INTEGEM
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Updated Date: November 23, 2022

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Camp Integem ("Integem") and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you") when you visit an Integem website, create an account, purchase an Integem product or your student participates in an Integem service/program (collectively, our "Services"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or device ("personal information"). In particular, we have collected the following categories of personal information from individuals that have visited our sites, purchased our products and applied for employment within the last twelve (12) months:

Examples of the type of information collected

Identifiers: Name, postal address, Internet Protocol address, email address, phone number, or other similar identifiers, personal meeting id.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Name, signature, address, telephone number, driver's license or state identification card number, education, employment, credit card number, credit card token, expiration date, CVV, or any other financial information, physical illness, mental illness or disabilities, allergies, immunizations, medications, social security number, Routing number, financial institution name, account number, CPR certification information, social media memberships, spam tags, number of posts, date joined.

Protected classification characteristics: Age, ethnicity, race, physical illness, mental illness or disabilities, gender, veteran status

Commercial information: Purchase history

Internet or other similar network activity: Access history and information on your interaction with our pages including, type of browser used, Internet Service Providers (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us). Cookies.

Professional or employment-related information: Occupation, employer information, experience

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 level, school attended, experience level

Geolocation data: Goelocation.

Audio, electronic, visual or similar information: Video recordings, telephone recording, profile pictures, photos. Many of our services require us to collect images and other information from your device's camera and photos. For example, you won't be able to use iCreator certain functions or iPlayer to design and test Holographic AR experience unless we can access your camera or photos.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from information you provide to us related to the Integem program you purchased, and your student participated in, or in an application for employment;

• Directly from an Agent, third party, vendor, or non-profit program. For example, when an Agent or non-profit program purchases services on your behalf, or we verify information through employment references, or location providers;

• Directly and indirectly from you when using our Services. For example, usage details collected automatically in the course of your interaction with our websites, social media or blog sites;

• Publicly available databases;

• Joint marketing partners, when they share information with us; and

• Social Networks, when you access our services through a link in Social Network.

II. Use of Personal Information

We DO NOT SELL any personal information. We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, to register at a location where the student is attending a course, to participate in a course online, to complete employment paperwork.

• To provide you with email alerts and other notices concerning our Services, or updates to your account or purchases.

• To allow you to use our site and Services.

• To improve our Services to you.

• For testing, research, analysis and product development.

• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

• For internal business purposes, including data analysis and audits.

• In conjunction with other sources of data (for example responses to surveys, clearinghouses, third party sites, etc.) to assess the quality and impact of our programs and to inform you of programs and Services which may be of interest to you, as well as ongoing planning and improvements.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

III. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. We engage certain trusted third parties to perform functions and provide services to us including, but not limited to hosting and maintenance, performance monitoring, billing, customer relationship, database storage and management, and direct marketing. If we share your Personal Information with these parties, we only share information that is necessary to perform the function the third party was hired to provide. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers;

• California Customer Records personal information categories;

• Protected classification characteristics under California or federal law;

• Commercial information;

• Internet or other similar network activity;

• Professional or employment-related information;

• Non-public education information;

• Geolocation information;

• Audio and visual information.

We disclose your personal information for a business purpose to the following categories of third parties:
You, your Agents, or non-profit partners with which you have an established relationship.

• Service providers, for example credit card processors, locations, Google Analytics and other analytical and data analysis services.

• Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services.

• Employment References.

• Marketing Services.

• Health Departments and other governmental agencies.

In the preceding twelve (12) months, we have not sold any personal information.

IV. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.

• Our business or commercial purpose for collecting that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

B. Deletion Request Rights
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at support@integem.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

D. Response Timing and Format
We will make every effort to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

E. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you use of our Services.

• Provide you a different level or quality of Services.

V. Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the top of this page. You are responsible for periodically visiting to check for any changes.

VI. Contact Information
If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at support@integem.com.