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CALIFORNIA EMPLOYEE PRIVACY NOTICE 

Last Updated and Effective September 1, 2023. 

Espire Dental (the “Company,” “we,” and “us”) have implemented this privacy policy  (“California Employee Privacy Notice”) for California residents and those seeking to  become a team member of the Company’s workforce. This California Employee Privacy  Notice is designed to assist California workforce members and candidates in understanding  how Espire Dental collects, uses, shares, and safeguards personal information as part of  your working relationship with us. 

To Whom this Workforce Member Privacy Policy Applies 

This California Employee Privacy Notice applies to individuals in connection with their  status as a workforce member or candidate. Our privacy practices with respect to personal  information collected in other contexts, including visiting any of Espire Dental’s websites and social media sites, can be found in the privacy policy or notice posted on those  websites. Please review those privacy policies to learn more about our general privacy  practices. 

Except as may be specifically required by law, this Workforce Member Privacy Policy does  not apply to information available from a public source or any information aggregated or  de-identified which we may collect about our workforce, nor to references to workforce  members in company work product. This Workforce Member Privacy Notice is intended to  comply with the California Consumer Privacy Act (“CCPA”), as updated by the California  Privacy Rights Act (“CPRA”). 

1. Updates 

This Notice will be updated from time-to-time to reflect changes in our business, legal or  regulatory obligations, so please check this Notice periodically for changes by  visiting https://www.espiredental.com. We will not collect additional categories of your  personal information or use your personal information already collected for additional  purposes without providing you with notice of our intent to do so. Any changes to this  Notice will be effective on the date we post the updated Notice to our website. 

2. Definitions: 

“You” or “Workforce member” means an identified or identifiable natural person who is  a California resident and who is acting as an Espire Dental or any Espire Dental affiliates  job applicant, employee, or contractor. In this context “job applicant” refers to any person  who has submitted his or her candidacy with Espire Dental; “employee” refers to any  person who is or was previously employed at Espire Dental as a full-or part-time employee,  temporary worker, owner, director, or officer; and “contractor” means a natural person  who provides any service to a business pursuant to a written contract or service  agreement.

Personal information” means any information that identifies, relates to, describes, is  reasonably capable of being associated with, or could reasonably be linked, directly or  indirectly, with a particular California resident or household. Personal information does  not include publicly available information or information that has been de-identified. 

3. Categories of Personal Information We Collect About You 

Espire Dental may collect the following categories of personal information about you: 

Identifiers: This includes a real name; postal address; email address; phone  number; emergency contact details; online account name and password; security  question and answer; birth certificate; children’s names; parents’ names; mother's  maiden name; marriage license; death certificate; passport number; national  identification number; driver's license number; social security number; tax ID  number; government identification card number; immigration/naturalization  number; retirement account number; beneficiary number; and National Provider  Identifier (NPI); personality traits, behaviors, responses and scores from third  parties. 

Note: Categories of personal information collected may also be deemed Customer  Records under California and will be included in the chart below as such. • Protected Classifications: This includes age; gender; birthplace; nationality; racial  or ethnic origin; citizenship status; marital status; family information; pregnancy;  disability status; criminal history; drug test results; tobacco use indicator; veteran  status; health and medical information. 

Commercial information: This includes vehicle make and model; vehicle license  plate number. 

Biometric Information: This refers to facial images/photographs; clothing size;  height; and weight, and physical characteristics used to identify individuals. • Internet/Network Activity. This refers to your interactions with Internet connected devices we control and use of our networks. This category includes the  browsing and search history on Company-owned or controlled networks, software  usage logs, and other information related to your use of Company-owned or  controlled devices, networks, and software applications. 

Geolocation/Location Data: This refers to general location information including  that collected from mobile devices and vehicles. 

Sensory Data: This includes audio, electronic, or visual information; which may  include video surveillance information; photographs; and other audio-visual  information. 

Professional or Employment-Related Information: This includes professional or  employment-related information, such as job title/role; employment identification  number; company/entity; office location; business unit/division; line/reporting  manager; employment status; start date; end date and reason for termination; exit  interview; hours of work; record of absence/time tracking/annual leave;  employment history; employment contract type; benefits and entitlements  information; health and safety related information and reporting; performance  rating; disciplinary action; grievances and complaints; salary/wage information; 

salary/wage expectation information; bonus payments; tax information; expense  and reimbursement information; workers compensation claims; job application  details; resume information; previous work history; and other employment  information; professional memberships; professional licenses;  

qualifications/certifications; malpractice insurance information; DEA certificate and  number; professional references; aptitude assessment results; LinkedIn profile  information; and resume cover letter. 

Education information: This includes education history; educational degrees;  academic transcripts/grades; training history; languages; and  

certifications/courses. 

Inferences drawn from other personal information that are used to make decisions  about an individual. This includes information reflecting a person’s preferences,  characteristics, psychological trends, predispositions, behavior, attitudes,  intelligence, abilities, and aptitudes. 

Sensitive Personal Information. The CCPA defines various categories of personal  information as “sensitive personal information,” including government IDs; precise  geolocation; payment card and bank account information, demographic  information; email contents (if Espire Dental is not the recipient); biometric  information; and health information. 

4. Notice at Collection 

At or before the time of collection, you have a right to receive notice of our practices,  including the categories of personal information to be collected, the purposes for which  such information is collected or used, whether such information is sold or shared and how  long such information is retained. You can find this information below. 

To clarify what categories of personal information we collect and the sources from which  we collect them, as well as if we share or sale this personal information, we have provided  the following chart. You can learn more about our specific practices by reading our more  detailed disclosures below the chart.

Categories of  

Personal  

Information

Categories of Sources  from which the  

Information was  

Collected

Categories of Third  Parties to whom this  type of Personal  Information is  

Disclosed for a  

Business Purpose

Types of Third  Parties with  

Whom this  

Category of  

Personal  

Information Is  Shared/Sold

Identifiers 

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human Resources Service Providers 

• Business Services  Providers 

• Governmental  

Entities

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human  

Resources  

Service  

Providers 

• Business  

Services  

Providers 

• Governmental  Entities

We do not sell or  share

Customer Records  (as defined in Cal.  Civ. Code §  

1798.80(e))

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human Resources Service Providers 

• Business Services  Providers 

• Governmental  

Entities

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human  

Resources  

Service  

Providers 

• Business  

Services  

Providers 

• Governmental  Entities

We do not sell or  share

Protected  

Classifications

• Workforce  

Members

• Workforce  

Members 

• Company  

Affiliates

We do not sell or  share

• Candidate  

Recruiting  

Partners 

• Governmental  

Entities 

• Company  

Affiliates

• Human  

Resources  

Service  

Providers 

• Business  

Operations  

Service  

Providers 

• Candidate  

Recruiting  

Partners 

• Governmental  Entities

Commercial  

Information

We do not collect  

commercial information  in the context of a  

workforce member  relationship.

We do not sell or  share

Biometric  

Information

• Workforce  

Members

• Workforce  

Members 

• Business  

Operations  

Service  

Providers

We do not sell or  share

Internet/Network  Activity

• Workforce  

Members 

• Business Services  Providers

• Workforce  

Members 

• Business  

Services  

Providers 

• Company  

Affiliates 

• Human  

Resources  

Service  

Providers

We do not sell or  share

Geolocation Data 

We may gather your  geolocation based on  your address, IP address, or other data associated  with a particular 

• Workforce  

Members 

• Business  

Services  

Providers

We do not sell or  share

location. If you are using  company-equipment that collects geolocation, we  may associate that  

geolocation with you.

• Company  

Affiliates 

• Human  

Resources  

Service  

Providers

Sensory Data 

We may collect your  image, voice, electronic  activity, or other sensory data through recording  devices such as a  

security camera or call  recording device.

• Workforce  

Members 

• Business  

Services  

Providers 

• Company  

Affiliates 

• Human  

Resources  

Service  

Providers

We do not sell or  share

Professional or  employment 

related  

information

• Workforce  

Members 

• Candidate  

Recruiting  

Partners 

• Human Resources Service Providers 

• Governmental  

Entities

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human  

Resources  

Service  

Providers 

• Business  

Services  

Providers 

• Governmental  Entities

We do not sell or  share

Education  

Information

• Workforce  

Members 

• Educational  

institutions 

• Candidate  

Recruiting  

Partners

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human  

Resources 

We do not sell or  share



Service  

Providers 

• Business  

Services  

Providers 

• Governmental  Entities

Inferences drawn  from other  

personal  

information

We do not collect  

inferences, but we may  make inferences about  workforce members  based on the personal  information we have  collected. For example,  we may make inferences  regarding a workforce  members’ suitability for  a particular position or  task.

We do not disclose  inferences we make  outside of the  

company, but we may  store inferred personal data with our Business  Service Providers (for  example, our cloud  storage providers).

We do not sell or  share

Sensitive Personal  Information

• Workforce  

Members 

• Candidate  

Recruiting  

Partners 

• Human Resources Service Providers 

• Business Services  Providers 

• Governmental  

Entities

• Workforce  

Members 

• Company  

Affiliates 

• Candidate  

Recruiting  

Partners 

• Human  

Resources  

Service  

Providers 

• Business  

Services  

Providers 

• Governmental  Entities

We do not sell or  share

We collect personal information about our workforce members from a variety of sources,  but primarily from the workforce members themselves. In addition, we gather personal  information through workforce members’ interaction with the Company’s systems and  personnel, and we receive personal information from third parties who provide it to us.  The following is a list of the sources from which we may collect personal information.

Candidate Recruiting Partners. This is anyone or entity who assists in facilitating  recruitment and review of candidates to become Espire Dental team members.  These entities include recruiting firms, job search services, social media companies  (e.g., LinkedIn), and professional recruiting agents. We may also collect personal  information from any other person or entity with whom you provide a reference, including past employers, personal references, former colleagues, and others. 

Human Resources Service Providers. This is anyone or entity who assists in  providing human resources and workforce management services, including  background check providers, human resources software services providers,  

insurance providers, employee payment and benefits providers, governmental  entities, and similar entities. 

Business Services Providers. This is anyone or entity with whom we have a  relationship to provide business operations services and support to the Company.  These providers may include the following: 

o IT Operations Providers. These include cloud computing service providers,  internet service providers, data backup and security providers, functionality  and infrastructure providers, and similar service providers. 

o Professional Service Providers. These include lawyers, accountants,  consultants, security professionals, and other similar parties when disclosure  is reasonably necessary to comply with our legal and contractual obligations,  prevent or respond to fraud or abuse, defend ourselves against attacks, or  protect the rights, property, and safety of us, our customers, and the public. 

o Operations Providers. These include service providers with whom we  partner to provide day-to-day business operations, including real estate  advisors, event planners, food services providers, entertainment providers,  payment processors, banks, facilities management providers. 

o Affiliates. Our affiliates include our parent company, subsidiaries, joint  venturers, or other companies that we control or that are under common  control with us. 

o Governmental Entities: These are governmental agencies that may provide  information about workforce members. 

We may also collect personal information from any other person or entity with whom you  interact in the scope and course of a workforce affiliation with the Company. For example,  we may collect personal information about you from customers, business contacts, and the  public. 

5. The Purposes for Which Your Personal Information Is Collected or Used We may collect or use personal information from you for the following business purposes: 

Espire Dental collects the personal information identified in Section 4 above for the  reasons listed below. 

• To Process Employment Applications and Onboard New Hires, including to conduct  employment related background screening and checks; and recruiting.

• To Credential Healthcare Practitioners, which includes both employee practitioners  and independent contractor practitioners for participation on insurance carrier and  managed care plan provider panels, including any legally required reporting to, and  queries of, national provider data banks. 

• To Administer Benefits, such as medical, dental, vision, wellness, EAP, life,  retirement benefits, and reimbursement and assistance programs, including  recording and processing eligibility of dependents, absence and leave monitoring,  insurance, and accident management. 

• To Pay and Reimburse for Expenses, including salary administration, payroll  management, payment of expenses, to administer other compensation related  payments, including assigning amounts of bonus payments to individuals. 

• To Conduct Performance-Related Reviews, including performance appraisals, career  planning, skills monitoring, job moves, promotions and staff re-structuring. • To Monitor Work-Related Licenses and Credentials, including provisioning licenses  for use during employee’s work-related responsibilities, ensuring compliance,  training, examination, and other requirements are met with applicable regulatory  bodies. 

• To Provide Our Employees with Human Resources Management Services, including  providing employee data maintenance and support services, administration of  separation of employment, approvals and authorization procedures, administration  and handling of employee claims, and travel administration. 

• To Maintain Your Contact Information, including altering your details across  relevant entities within Espire Dental and affiliated entities (for example personal,  other employment and transferring roles). 

• To Assist You in Case of Emergency, including maintenance of contact details for  you, and your dependents in case of personal or business emergency. • To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring  compliance of employees’ ability to work in the U.S. 

• To Conduct Healthcare-Related Services, including conducting pre-employment and  employment-related medical screenings for return-to-work processes and medical  case management needs; determining medical suitability; identifying health needs  of employees to plan and provide appropriate services, including operation of  sickness policies and procedures. 

• To Facilitate a Better Working Environment, which includes conducting staff  surveys, providing senior management information about other employees, and  conducting training. 

• To Ensure a Safe and Efficient Working Environment, which includes Espire actions  relating to disciplinary actions, and code of conduct processes and investigations. • To Maintain Security on Espire Dental Websites and Internet Related Assets, which  includes hosting and maintenance of computer systems and infrastructure;  management of Espire software and hardware computer assets; systems testing,  such as development of new systems and end-user testing of computer systems;  training; and monitoring email and Internet access. 

• To Comply with Applicable Law or Regulatory Requirements, such as legal (state  and federal) and internal company reporting obligations, including headcount by 

ethnicity and gender, management information, demographic and health, safety,  security, and environmental reporting. 

• For other employment and HR purposes, such as assessing a job applicant’s  credentials and work experience. 

Any information collected is disclosed to you here and is used as permitted or required by  law. 

6. Disclosure of Personal Information 

We may disclose personal information to any of the entities identified as sources of  personal information. We may also disclose any personal information to the following: 

Customers. We disclose personal contact information to customers as part of the  normal customer service relationship. 

Company Affiliates. We disclose personal information about our workforce  members to other entities affiliated with the Company, including our parent and  subsidiary companies. 

Legally Required Parties. Persons to whom we are required by law to provide  information, such as pursuant to a subpoena or a court order. 

Reorganization Recipients. Persons involved in the consideration, negotiation,  completion of a business transaction, including the sale, merger, consolidation,  acquisition, change in control, transfer of substantial assets, bankruptcy, or  reorganization, and any subsequent integration. 

Authorized Recipients: To any party when authorized by the individual to whom it  pertains to share it. 

7. Data Retention 

We retain personal information for various periods depending on the nature of the  personal information, the purposes for its collection and use, and based on our legal and  ethical obligations. Generally, we retain personal information only for so long as necessary  to fulfill the purposes for which we collected it. To determine the appropriate retention  period for personal information, we consider the amount, nature, and sensitivity of the  personal information; the potential risk of harm from unauthorized use or disclosure of  your personal information; the purposes for which we process your personal information  and whether we can achieve those purposes through other means; and the applicable legal  requirements. 

8. Your California Privacy Rights 

California Residents have certain rights under the CCPA. For information on how Espire  Dental exercises these rights, please see below. 

The Right to Know. The right to know what personal information the Company has  collected about you, including the categories of personal information, the categories 

of sources from which the personal information is collected, the business or  commercial purpose for collecting, selling, or sharing personal information, the  categories of third parties to whom the business discloses personal information, and  the specific pieces of personal information the business has collected about you. 

The Right to Deletion. The right to delete personal information that the business  has collected about you, subject to certain exceptions. 

The Right to Correction. The right to correct inaccurate personal information that  a business maintains about a California resident. 

The Right to Opt-Out of the Sale/Sharing. If we sell or share personal information,  the right to opt out of the sale or sharing of your personal information by the  Company. 

The Right to Limit the Use of Sensitive Personal Information. If the Company  uses or discloses sensitive personal information for reasons other than those  permitted by the CCPA, the right to limit the use or disclosure of sensitive personal  information by the Company. 

Non-Discrimination. The right not to be discriminated against for exercising any of  the rights conferred by the CCPA. 

Espire Dental will honor the privacy rights afforded to individuals in accordance with  applicable law. 

Exercising Your CCPA Rights 

Workforce Members who are California residents may submit CCPA requests themselves or  using an authorized agent. CCPA requests are subject to our verification measures which  vary depending on the type of request made and the sensitivity of the information you  request. We may ask you to provide information to confirm your identity in our records. If  you authorize an agent to submit a request on your behalf, we may require the agent to  provide proof that you gave the agent signed permission to submit the request and may  verify the agent’s identity and authority to act on your behalf. 

Submitting Access, Deletion, and Correction Requests 

To make a right to know (access), deletion, or correction request, please submit a CCPA  request form or call our dedicated toll-free CCPA request phone number at 888-508-2033. 

Limiting the Use of Your Sensitive Personal Information 

Californian’s have the right to limit a business’s use or disclosure of sensitive personal  information. However, the Company does not use or disclose sensitive personal  information for any purpose other than for permissible purposes under the CCPA.  Therefore, we do not offer a mechanism to submit these requests. 

Opting Out of the Sale/Share of Your Personal Information

The Company does not sell or share personal information related to the workforce member  relationship. Please review the privacy policies located on our Company websites for more  information about opt-out rights for website visitors. 

9. How Do I Contact Espire Dental with Questions About the CCPA Employee  Privacy Notice? 

If you have any questions about this CCPA Employee Privacy Notice, please email us  at: HR@EspireDental.com.