Effective Date: June 27, 2022

Ace Group International, LLC (“AGI”) is committed to protecting the privacy and security of your personal information. This Privacy Policy (the “Policy”) describes how AGI collects and uses personal information about you, specifically during the job application process through the third-party Paycom platform (the "Services"), in accordance with applicable data protection laws.

This Policy does not form part of any contract of employment or other contract and does not confer any employment status or contractual right on you, or place any contractual obligation on us. We may update this Policy at any time.

It is important that you read the AGI Job Candidate Privacy Policy, so that you are aware of how and why we are using such information.

This Privacy Policy explains the following:

• How we collect information
• The types of information we collect
• How we collect information automatically
• How we use your information
• How we share your information
• How we protect and store your information
• Your Privacy Options
• Jurisdiction-specific Notices
  • California Residents
  • Residents of the EEA, Switzerland, or UK
• Updates to this Privacy Policy

Please note that this Privacy Policy does not apply to the collection of information on other AGI websites or services that state that they are offered under a different privacy policy. Please review the privacy policies on those websites directly to understand their privacy practices.

For questions about our privacy practices, contact us at privacy@acehotel.com.

1. How We Collect Information

We may collect information about you by following means:

• Directly from you, when you provide information to us or interact with us or the Services;
• Automatically from you, when you utilize or interact with our Services.

2. Information We Collect

In order to better provide you with our Services, we may collect the following categories of information:

• Contact information and any other information you choose to include when you apply for a job position with us;
• Profile information, such as a username and password, your name, mailing address, e-mail address, phone number;
• Online User Activity described in the next section;
• Biographical information when you inquire about or apply for a position with us, such as education and work history.

Some of this information may be collected by external parties on our behalf.

If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this policy.

3. Online User Activity and Information Collected by Other Automated Means

When you interact with the Services, certain information about your use of our Services is automatically collected. This includes:

• Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device's telephone number).

4. How We Use Your Information

We use the information we collect from you for the following purposes:

• Provide the Services to you, including to maintain your account;
• Evaluate, recruit, and hire personnel;
• Respond to your requests, questions and comments and provide support;
• Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns;
• Comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of AGI, you, or others.

We may use and share information in an aggregated or de-identified manner at our discretion, including for research, analysis, modeling, marketing, and improvement of our Services.

5. How We Share Your Information

• We may share your information with service providers that we believe need the information to perform a technology, business, or other professional function for us such maintenance and hosting of our Services and other professional services.
• We may partner with analytics providers, who collect information via tracking technologies on our websites to assist us with measuring visits and traffic on our websites so we can measure and improve the performance of the sites.
• We share information with other entities in our corporate family, for purposes consistent with this Privacy Policy.
• We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
• We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third-parties, as permitted by law and without your consent when it is necessary to protect our customers, employees, or property, in emergency situations; or to enforce our rights under our terms of service and policies.

6. How We Protect and Store Your Information

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may differ from the laws of your jurisdiction.

7. Your Privacy Options

You may have certain choices when it comes to how we collect and use your information:

• Email Communications. If at any time you no longer wish to receive email communications about your application for employment, you can email us at privacy@acehotel.com.
• Disclosure to Third Parties for Marketing Purposes. You may opt-out of disclosure of your information to third parties who offer products and services you may be interested in by emailing us at privacy@acehotel.com.

8. Jurisdiction-Specific Notices

A. California Residents: Your California Privacy Rights

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties for those third parties’ own direct marketing purposes. If you are a California resident, you may opt-out of such sharing by emailing us at privacy@acehotel.com.

B. California Residents: California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights.

To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. The categories we use below to describe the information are those enumerated in the CCPA.

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement.

Entities to whom we “sell” information are third parties. Under the CCPA, a business “sells” personal information when it discloses it to a company for monetary or other benefit. A company may be considered a third party either because the purpose for its sharing of personal information is not for an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for other purposes.

When you apply for a job with AGI, information may be collected about you in multiple ways: you may provide it to us in connection with your application; we may make observations in the application process or collect information from public information sources; or you may authorize us to collect information from other sources, such as a former employer or reference.

The following table describes our practices with regard to information submitted in the job application process. The sources of this Personal Information are described in the Information We Collect section above. We collect this Personal Information for the purposes described in the “How We Use Your Information” section above.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Right to Know and Request Access to and Deletion of Personal Information

You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You also have the right to request in certain circumstances that we delete personal information that we have collected directly from you. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

How to Submit a Request

You may submit a request to exercise your rights to know/access or delete your Personal Information by emailing us at privacy@acehotel.com.

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf.

C. Special Information for Residents of the EEA, Switzerland, or the UK

If you are located in the EEA, Switzerland, or the UK, you are entitled to certain rights, subject to applicable exceptions, under the GDPR, Swiss, and UK data protection laws. Please note that, in order to verify your identity, we may require you to provide us with information prior to accessing any records containing information about you.

We typically will process your information pursuant to the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; or (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy. We also may process your information where it is necessary to comply with a legal obligation to which we are subject.

• Right of Access: You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, request a copy of the personal data. If you would like a copy of the personal data that we hold about you, please send a description of the personal data you would like a copy of and proof of your identity to our email as set forth below.
• Right to Correction: You have the right to correct any inaccuracies in the personal data that we hold about you and, where applicable, to complete any incomplete personal data that we hold.
• Right to Erasure: You have the right to request that we erase the personal data that we hold about you if one of the conditions in Article 17 of the GDPR applies. The right to erasure does not apply in certain circumstances, including where the processing is necessary for the establishment, exercise, or defense of legal claims.
• Right to Restriction of Processing: You have the right to restrict our processing of your personal data if one of the conditions in Article 18 of the GDPR applies.
• Right to Data Portability: You have the right to receive personal data concerning you in a structured, common, and machine-readable format or request transmission of the data to a third party, if the conditions in Article 20 of the GDPR are met.
• Right to Object: You have the right to object to the processing of your personal data based on our legitimate interests at any time. We will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights, and freedoms of the data subject, or the processing serves the purpose of asserting, exercising, or defending legal claims. You also have the right to object at any time to the use of your data for direct marketing.
• Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

To submit a request to exercise your rights, please email us at privacy@acehotel.com. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Cross-border Transfer of Data

If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.

Lodging a Complaint

Users that reside in the EEA, Switzerland, or the UK have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

9. Updates to This Privacy Policy

We may make changes to this Policy from time to time. The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised. We may also notify you in other ways from time to time about the collection, use, and disclosure of your personal information described in this Policy.