APPLICABILITY OF THIS PRIVACY NOTICE

Atrium Staffing LLC and its Affiliates (collectively “Atrium”) value and respect your privacy and are committed to protecting it through our compliance with this Privacy Notice. This Privacy Notice (the “Notice”) describes the use and disclosure of information Atrium collects from you or provided by you when you visit the following Atrium (https://www.atriumstaff.com and https://www.atriumglobal.com) websites, and together with any materials and services available therein, and successor site(s) thereto (collectively the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. In addition, this Notice governs all areas of employment at Atrium, including recruiting, hiring, training, training assignments, placement, promotions, compensation, benefits, discipline, layoff, recall, transfer, leaves of absence, and terminations.

If you are a citizen or resident in the United States (US) or Canada, please review our Privacy Notice below. For California employees or potential employees, please also review our supplemental Employee Privacy Notice for California Residents.

Note for EEA and UK Website Visitors Only. This Privacy Notice applies to individuals who are residents of the European Economic Area (EEA) or the United Kingdom (UK) only to the extent that they visit or interact with Atrium’s Website. For EEA or UK residents, this Notice governs Atrium’s collection and processing of personal information in connection with website use, including browsing, submitting online forms, or otherwise engaging with online content. Atrium processes such personal information where necessary to perform its legitimate business interests in operating, maintaining, and improving the Website, to respond to inquiries or requests initiated by you, and, where required by law, based on your consent. This Privacy Notice does not apply to EEA or UK residents in the context of offline activities or employment-related processing, which may be governed by separate privacy notices, contractual terms, or applicable local laws.

This Notice discloses Atrium’s privacy practices and expresses our commitment to keeping you informed on how Atrium collects and uses your personal information. This Notice applies to all personally identifiable information Atrium handles in connection with the Website. This Notice also sets forth Atrium’s information gathering and dissemination practices for the Website. Within this Notice, Atrium informs you about:

• Types of information Atrium collects
• How such information is collected
• The general purposes for which such information is collected
• What disclosures of information will be made by Atrium
• How and to what extent you can limit such disclosures
• Resources to ask questions or complaints

NOTE FOR USE OF ARTIFICIAL INTELLIGENCE TOOLS
In connection with the personal information collected and used as described in this Privacy Notice, Atrium may use artificial intelligence-enabled tools to support certain aspects of its recruitment, hiring, and workforce management processes. Atrium’s use of such tools does not replace human review or decision-making. Additional information is available in Atrium’s AI Transparency Notice at https://www.atriumstaff.com/ai-transparency-notice/.

MANAGE YOUR INFORMATION

Email Preferences

Opt out of marketing e-mails globally (i.e., across our brands) by clicking on the following link and filling out the form accordingly.

Update Email Preferences

Manage Your Cookies

We collect and use data-including, where applicable, your personal data-for the purposes listed below. Update Your Cookie Preferences

Delete Your Data

Permanently delete your information.

Update Data Preferences

Control Over Your Data

For additional ways to delete, opt out, or manage your information, please see the “Your Rights and Choices.” Section of this Privacy Notice.

PLEASE READ THIS NOTICE CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING HOW WE WILL TREAT YOUR PERSONAL INFORMATION AND PRIVACY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR WEBSITE.

Atrium is committed to ensuring that you receive the highest level of security, both through our websites and internally within our company.

SCOPE

This Notice applies to natural persons only. “Natural persons” refer to individuals who are living human beings, as opposed to legal entities or organizations. This Notice sets out the rights and obligations related to the privacy of personal information, specifically concerning individuals.

COLLECTION OF PERSONAL INFORMATION

Through our Website or through other technological means, Atrium collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information” or “Personal Data”), such as:

• In email, text, and/or any other electronic messages between you and the Website.
• When you interact with advertising and applications on third-party websites and services if those applications or advertising include links to this Notice.

This Notice does NOT apply to information collected by:

• Atrium offline or through any other means, including on any other website operated by Atrium or any third-party (including other affiliates and subsidiaries); or
• Any third-party (including other affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

CATEGORIES OF INFORMATION COLLECTED

As a career and employment services business, Atrium collects personal information, including Internet Protocol (IP) address(es), your name, address, telephone numbers, schools attended, e-mail address(es) and companies worked for, as well as other relevant information for prospective employment with Atrium or Atrium clients who will become your future employer.

The amount and type of information that Atrium gathers depends on the nature of the interaction. Atrium does not disclose personal information in ways other than as described herein. You can always refuse to supply information, with the caveat that it may prevent you from receiving certain Atrium services.

Categories of Information collected:

• Identifierssuch as a real name, alias, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Personal Information, such as a name, signature, Social Security Number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information.
• Protected Classes of Information, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Commercial Information, such as services purchased, obtained, or considered.
• Internet Activity, such as information on a consumer’s interaction with a website or advertisement.
• Professional or Employment Related Information, such as work experience, union membership. resume, educational history, or references. For employees, or potential employees, residing in California, please see the CCPA Privacy Notice for California Employees.
• Non-Public Education Information, such as education records directly related to a student or former 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.
• Inferences Drawn from Other Personal Information, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• For Sensitive Information, some states place greater requirements on the collection and processing of sensitive personal information. Atrium may be required to collect the Sensitive information listed below due to the nature of the business relationship or interaction with the individual:
  • Sensitive Identifiers, including SSNs, driver’s license, state/government ID cards, passport numbers
  • Precise Geolocation
  • Demographic Information, including race, ethnicity, philosophical beliefs, religious beliefs, and sexual orientation
  • Financial Information, including account log-in, financial account number, debit or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
  • Medical Data, including genetic, biometric, and health data
  • Employee Data, including union membership
  • Immigration Information

METHODS IN WHICH ATRIUM OBTAINS INFORMATION FROM YOU

Atrium obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or services we provide you. This is an example of opting in to process information about you to provide you with services, such as employment placement.
• Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
• Third parties.For example, staffing and recruiting agencies with whom we contract for services, and consumer reporting agencies when we perform employee background screenings.

PURPOSE & USE OF PERSONAL INFORMATION

Atrium may share your name and relevant information with Atrium’s clients after hire. Due to the nature of the employment-related services Atrium provides, most visitors to the Website choose to provide personal information. Atrium may use the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job or become an employee, we will use that personal information in connection with your employment or potential employment.
• To contact you and to inform you about benefits or information relating to your employment or potential employment.
• To provide, support, personalize, and develop our website and services relating to your employment or potential employment.
• To create, maintain, customize, and secure your information or account with us.
• To process your requests or transactions and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns, and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our systems, Website, services, databases, and other technology assets, and business.
• For research, analysis, and business development, including the development and improvement of our business processes, website, and services.
• 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 subsequently agreed to by you.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Atrium’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Atrium about our Consumers is among the assets transferred.

For the purposes stated above, some of the ways Atrium may use your personal information include:

• Screening and submitting resumes for filling client positions
• Meeting contractual obligations, such as providing required personal data to our third-party employee benefits administrators
• Complying with employer-related reporting obligations to the city, state, federal government, or other agencies as required by law;
• Conducting contests, sweepstakes, or other marketing and promotional activities posted on the Website
• Obtaining feedback from applicants, candidates, employees, or clients
• Collecting new hire onboarding paperwork
• Creating a talent community
• Website analytics

Atrium 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.

Atrium conducts most of its business electronically and by telephone. You will need to provide Atrium with your email address and contact telephone number for us to contact you. Atrium will not share your e-mail address or telephone number with others outside of Atrium except for employment recruiting and employment purposes.

WHERE ATRIUM STORES YOUR PERSONAL INFORMATION

Atrium has offices in multiple jurisdictions (the US, Canada, the UK, and the EEA), and your personal information may be stored or processed outside your home country. We have networks, databases, servers, systems, support, and help desks at our offices. For Atrium’s full list of office locations, please visit https://www.atriumglobal.com/locations/

If you utilize the Website from a country other than the country where Atrium’s servers are located, your communications with us may result in you transferring your personal information across international borders to such Atrium servers. Also, when you contact Atrium, Atrium may provide you with support from Atrium locations that may be outside of your country of origin. In these cases, your personal information is handled in accordance with this Notice and applicable laws.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Atrium may disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to:(a) conform to legal requirements or comply with legal process served on Atrium, including, but not limited to, compliance with legal, regulatory, and law enforcement requests. In such instances, Atrium will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Atrium will disclose any information about you to government or law enforcement officials or private parties as Atrium, in our sole discretion, believes is necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect Atrium property and rights or the property and rights of a third-party, to protect the safety of the public or any person, or to prevent or stop activity Atrium considers to be illegal or unethical.

Depending on your employment relationship with Atrium (e.g., candidate, or referred payroll worker), Atrium may share your profile, including your resume and relevant application details, and details necessary to manage the employment relationship (e.g., benefits or payroll) with our clients who are hiring for roles that match your experience. We aim to share only the information necessary to support your candidacy and will do so in accordance with applicable data protection laws.

To the extent Atrium is legally permitted to do so, Atrium will take reasonable steps to notify you in the event that Atrium is required to provide your personal information to third parties:

• (a) as part of a legal or employment process;
• (b) protect and/or defend Atrium rights or property;
• (c) protect the personal safety of its personnel or users of the public in appropriate circumstances; or
• (d) If Atrium and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if Atrium undergoes some other change, including a change to its corporate form as part of a bankruptcy proceeding or otherwise, information may be transferred as part of that transaction or change.

Any data and personal information that you volunteer or that is otherwise collected may be shared with our affiliated companies that Atrium owns or controls, service providers that Atrium contracts, other authorized third-parties when appropriate, based on Atrium discretion in order to transact business, provide requested services, comply with city, state, and federal rules, regulations and to enforce and apply this Notice or other applicable terms.

Atrium does not sell, share, or rent your personal information as defined under enacted state-specific privacy laws. However, specifically for visitors to Atrium’s website, our use of third-party cookies, tags, and other tools may be considered a “share” or “sale” of your personal information (please see “WEBSITE VISITORS: Cookies and other Online Identifiers” section below for more information).

YOUR RIGHTS AND CHOICES

Depending on where you reside, you may have certain rights and choices related to your personal information. Atrium will not discriminate against you in any way if you choose to exercise any of the above rights. Please note that the rights and choices listed below apply only to individuals in the US and Canada, and to the residents of the UK and the EEA, and that any rights available to you may depend on applicable state or other applicable legal frameworks.

**Note for Canadian Residents only: For requests under this section related to employment personal information, the following rights and choices apply only to British Columbia residents. For more information on rights available to Canadian residents, please visit the Office of the Privacy Commissioner of Canada’s Summary of Privacy Laws in Canada.

Right to Access

You have the right to request that Atrium disclose certain information to you about our collection and use of your personal information over the past 12 months. Once Atrium receives and confirms your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the 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).

At this time, Atrium does not sell, rent, or share your information for any monetary or beneficial gain. No valuable consideration is offered or received for your personal information. In the event we change our data sharing practices, we will provide you with notice. Furthermore, an access request shall identify two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Correct or Amend

You have the right to correct or amend information about you. When exercising the right to amend, individuals may request modifications to incorrect, outdated, or incomplete information to ensure its accuracy and relevance.

Right to Erasure or Deletion

You have the right to request that Atrium delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Section Exercising Access, Data Portability, and Deletion Rights below), Atrium will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Before Atrium can proceed with the deletion request of your information, Atrium must verify your identity. To do this, Atrium will ask you to confirm information previously collected about you.

To submit a request, please complete our Data Subject Request Form.

Atrium may refuse your request if permitted by law to keep any information, or if applicable law otherwise permits Atrium to keep information. Atrium will provide details in the event a request is denied.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• 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.

Right to Data Portability

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Accessing and submitting a Data Subject Request Form.

Only you can make a verifiable data subject request unless your state allows an authorized agent or entity to act on your behalf. You may also make a verifiable consumer request on behalf of your minor child. Please see the chart above to determine whether your state allows the submission of a verifiable data subject request via an authorized agent.

You may submit a verifiable request for access or data portability twice within a 12-month period preceding the receipt of the request.

The verifiable individual 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.

Atrium 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 that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

Atrium will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Right to Opt-Out

You have the right to opt-out to processing, or continued processing, of personal information under different circumstances depending on which state you reside in. By exercising their right to opt out, individuals can request that their data no longer be used for certain purposes, such as marketing or third-party sharing.

For instructions on exercising opt-out rights for cookies and other online identifiers for non-essential or targeting cookies, please review the “WEBSITE VISITORS: Cookies and other Online Identifiers” section.

WEBSITE VISITORS

Cookies and other Online Identifiers

As you interact with the Website through Atrium’s online resources, Atrium may also collect information about your browsing history or certain other information that is not considered personal information through your use of and visits to these resources through a variety of technologies, including, but not limited to, cookies, tags, beacons, Internet Protocol (IP) address, and other tools.

“Cookies” are pieces of code or text placed on your computer when you browse a website. Cookies may be placed by Atrium or Atrium’s web analytics third-party vendors or partners.

“Tags” and web beacons refer to code scripts that are primarily used to track visitor activities by web analytics software. The types of non-personal data collected on the Website through the use of these, and other tools may include the search terms you used, new or returning users, browser information, computer type, operating system, internet service providers, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, ads viewed, among other non-personal data (collectively, all of the foregoing data is considered “Non-Personal Data”).

Additionally, cookies, tags, and other tools placed by our web analytics third-party vendors or partners may collect other information about you and your visits to websites and elsewhere on the Internet, including, but not limited to, other Non-Personal Data.

Under the CCPA and other state laws, Atrium’s use of third-party cookies, tags, and other tools could be considered a “share, rent, or sale” of your personal information for website visitors. If you are a resident of California or another jurisdiction with similar laws, that means you have the right to opt out. Please see “Right to Opt-out” of this Privacy Policy. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following opt-out weblink: Do Not Sell My Personal Information.

As with most websites, Atrium collects non-personal information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non-personal information is to better understand how our visitors use the Website. From time to time, Atrium may disclose non-personal statistical information in the aggregate, e.g., by publishing a report on trends in the usage of its Website.

Additionally, Atrium may collect, store, and process any information and data that you volunteer to us, e.g., when you apply for a position, submit your resume, request information, complete forms, participate in online surveys, discussion groups or forums or interact with our website.

AGGREGATED STATISTICS

Atrium may collect statistics about the behavior of visitors to the Website. For instance, Atrium may monitor the most popular web pages visited or use spam screening technology to help us identify spam (unsolicited e-mail). Atrium may display aggregated information publicly or provide it to others. However, Atrium does not disclose personal information other than as described herein.

ALERTS AND NOTIFICATIONS

Atrium may use your email address, mobile phone number, and other contact information to alert you of job openings, profiles, articles, news, and other employment-related information, as well as to notify you of special promotions or additional products and services offered by us or Atrium affiliates and partners.

If you do not want us to use your contact information, which would include your email and or mobile phone number, to alert you of job openings, please complete our Data Subject Request Form.

SECURITY OF YOUR PERSONAL INFORMATION

Atrium is committed to protecting the personal information you share with Atrium. Atrium uses a combination of industry-standard security technologies, procedures, and organizational measures to help protect your personal information from unauthorized access, use, or disclosure. However, no information transmitted on the internet or stored on servers is 100% secure. As a result, Atrium cannot guarantee that any information covered by this Notice will be absolutely secure.

CHILDREN’S PRIVACY

Our Website is not intended for children under 13 years of age. No one under 13 years of age may provide any information to or on the Website. We do not knowingly collect personal information from children under 16 years old, and we do not “sell” or “share,” as those terms are defined under applicable state-specific privacy laws.

If you are under 13, do not use or provide any information on the Website or through any of its features, register on the Website, use any of the interactive or public comment features of the Website, or provide any information about yourself to Atrium, including your name, address, telephone number, email address, or any screen name or username you may use. If Atrium learns it has collected or received personal information from a child under 13 without verification of parental consent, Atrium will delete that information. If you believe Atrium might have any information from or about a child under 13, please contact us at HR@atriumglobal.com.

If you are a resident of California, under the age of 18, and a registered user of our services, you may ask us to remove content or information that you have posted to these services by contacting Atrium’s Human Resources Department at HR@atriumglobal.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

SHINE THE LIGHT

If you have an established business relationship with us, you may have rights to know how your information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which Atrium shared such personal information for the immediately prior calendar year (e.g., requests made in 2020 will receive information about 2019).

To exercise your rights, please submit a Data Subject Request. Atrium will respond to your request within forty-five (45) days.

LINKS TO OTHER SITES

The Website may contain links to other websites, or Atrium e-mail messages may contain privacy provisions that differ from the provisions of this Notice. To ensure your privacy is protected, Atrium recommends that you review the privacy statements of these other linked sites, applications, or other digital platforms. Atrium is not responsible for the privacy practices or the content of other websites outside of Atrium.

RETENTION OF PERSONALLY IDENTIFYING INFORMATION

Atrium will not retain your personal information longer than is necessary to fulfill the purposes for which it was collected, including storage or archival purposes, or as required by applicable laws or regulations. Unless otherwise required by applicable law, Atrium will remove such information from our systems and records or take appropriate steps to properly anonymize it.

CHANGES TO THIS PRIVACY NOTICE

The “Last Updated” date shown above indicates the most recent revision of this Notice. We reserve the right to make changes to the Website, including discontinuing or modifying parts of the Website or providing new opportunities to users, without incurring any liability. Any modifications to the Notice will be posted on the Websites, and once posted, they will become effective. By continuing to use the Websites after these changes have been made, you indicate your acceptance of the revised Notice.

UPDATING OR CORRECTING YOUR INFORMATION

In the event that your information changes, please contact your Atrium representative so that the necessary updates can be made to your information.

EQUAL EMPLOYMENT OPPORTUNITY STATEMENT

Atrium provides equal employment opportunities to all employees and applicants for employment without regard to race, color, creed, religion, sex, sexual orientation, gender identity or expression, national origin, age, citizenship, genetics, disability, veteran status, or any other characteristic protected status. This Notice governs all areas of employment at Atrium, including recruiting, hiring, training, training assignments, placement, promotions, compensation, benefits, discipline, layoff, recall, transfer, leaves of absence, and terminations.

QUESTIONS / CONTACTING US

Should you have any questions regarding this Notice, or our data handling practices, you may contact our Privacy Administrator by e-mail at privacyadministrator@atriumglobal.com, or by writing to us at:

Attn: Privacy Administrator
Atrium Staffing LLC
250 Vesey Street
21st Floor, Suite A
New York, NY 10281
212.292.0550

Atrium will attempt to resolve any inquiry regarding the use of your personal information in accordance with this Notice and will respond to all requests, inquiries, or concerns within forty-five (45) calendar days. If we require additional time or are unable to act on your request, to disclose and or delete your personal information as provided under applicable law, we will inform you without undue delay.

DATA PROTECTION AUTHORITIES

Subject to applicable law, you also have the right to ask questions or lodge a complaint with your local Data Protection Authority, depending on where you reside.

For UK Residents, you may direct questions or complaints to:

UK Information Commissioner’s Office (ICO)
Wilmslow, Cheshire, United Kingdom
SK9 5AF
0303 123 1113
https://ico.org.uk

For EEA Residents, you may direct questions or complaints to our lead EEA Supervisory Authority at:

Data Protection Commission (DPC) of Ireland
21 Fitzwilliam Square South
DUBLIN 2, D02 RD28
(01) 765 01 00
https://www.dataprotection.ie/