California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements TIPTOP RESTORATION INC. Website Privacy Policy and applies solely to California Consumers. This Statement does not apply to TIPTOP RESTORATION INC. personnel. Sections 2-5 of this statement do not apply to job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1.  Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; telephone number; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, or other similar identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, insurance policy number, education, bank account number, credit card number, and debit card number

• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements

• Geolocation Data

• Sensory Information: audio, electronic, and similar information

• Employment Information: professional or employment-related information

• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)

• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Website Privacy Policy and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

• Debugging to identify and repair errors that impair existing intended functionality

• Undertaking internal research for technological development and demonstration

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

• Managing career opportunities with TIPTOP RESTORATION INC.

2.  Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you purchase TIPTOP RESTORATION INC. products or services

• Your devices, such as when you visit our websites

• Your family or friends, such as when they provide us with your contact information so we can send information that may interest you

• Other TIPTOP RESTORATION INC. entities and franchisees

• Insurance companies

• Vendors who provide services on our behalf

• Online advertising services and advertising networks

• Data analytics providers

• Operating systems and platforms

3.  Sale of Personal Information

We do not sell your personal information in exchange for monetary consideration. We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our websites in exchange for non-monetary consideration. We share the categories of personal information listed below for online advertising purposes and to provide third-party social network features and functionality on our Sites. You have the right to opt-out of this disclosure of your information, which may be considered a “sale” under California law.

During the 12-month period prior to the effective date of this Statement, we may have sold the following categories of personal information about you to online advertising services and social networks:

• Identifiers

• Online Activity

• Inferences

We do not have actual knowledge that we sell personal information of minors under 16 years of age.

4.  Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

5.  California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request.  To submit an access, deletion or opt-out of the sale of your personal information request, click here or call us at call us at 1-800-788-1196.  To submit a request as an authorized agent on behalf of a consumer, click here or call us at call us at 1-800-788-1196. For questions or concerns about our privacy policies and practices, please contact us as described in the Contact Us section of our Website Privacy Policy. To submit a Shine the Light request, email us at info@tiptoprestoration.com.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: name, address, email address, phone number, dates of service, date of loss, type of loss, and insurance carrier name. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

HR Privacy Notice and Policy for California Residents Including

Employees and Applicants for Employment

Effective Date: January 1, 2023

TIPTOP RESTORATION INC. and its subsidiaries that share common branding (collectively, “TIPTOP RESTORATION INC.”) respect your concerns about privacy. This HR Privacy Notice describes the types of personal information we collect about California residents who are (1) TIPTOP RESTORATION INC. employees, owners, directors, officers, medical staff members and contractors (collectively, “TIPTOP RESTORATION INC. Personnel”), (2) emergency contacts of TIPTOP RESTORATION INC. Personnel, (3) individuals related to TIPTOP RESTORATION INC. Personnel for whom TIPTOP RESTORATION INC. administers benefits, and (4) job applicants (collectively with TIPTOP RESTORATION INC. Personnel, “HR Covered Individuals”).

TIPTOP RESTORATION INC. Personnel are responsible for providing this Privacy Notice to any HR Covered Individual whose personal information is provided to TIPTOP RESTORATION INC. by TIPTOP RESTORATION INC. Personnel. Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Personal Information We Collect

TIPTOP RESTORATION INC. may collect the following categories of personal information about HR Covered Individuals:

• Identifiers: identifiers, such as a real name, alias, postal address, unique personal identifier (e.g., a device identifier, employee number, unique pseudonym, or user alias/ID), telephone number, online identifier, Internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, date of birth, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number and debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Biometric Information
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites or applications
• Geolocation Data
• Sensory Information: audio, electronic, visual, thermal, and similar information
• Employment Information: professional or employment-related information, such as compensation, benefits and payroll information (e.g., salary-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to your position (e.g., job title and job description), performance-related information (e.g., evaluations and training), talent management information (e.g., resumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information), emergency contact information, and dependent information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

How We Use the Personal Information

We use personal information for the purpose of carrying out and supporting HR functions and activities, including the uses described below. In addition to general HR purposes, the purposes listed below also include relevant “business purposes” as they are described in the CCPA.

Managing work activities and personnel generally, including recruiting; performing background checks; determining suitability for employment or promotion; determining physical and/or mental fitness for work; reviewing and evaluating performance; determining eligibility for and processing salary increases, bonuses, and other incentive-based compensation; providing references; managing attendance, absences, leaves of absences, and vacations; administering payroll services; reimbursing expenses; administering health, dental, and other benefits; training and development; making travel arrangements; securing immigration statuses; monitoring staff; creating staff directories; investigating suspected misconduct or non-performance of duties; managing disciplinary matters, grievances, and terminations; reviewing staffing decisions; and providing access to facilities.

Ensuring business continuity; protecting the health and safety of our staff and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities, and other property; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency.

• Operating and managing our IT, communications systems and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; managing mergers, acquisitions, sales, reorganizations or disposals and integration with business partners.

Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; conducting investigations; and complying with internal policies and procedures.

Performing services.

Auditing related to a current interaction with you and concurrent transactions.

Certain short-term, transient uses.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Amendments

TIPTOP RESTORATION INC. may amend this Policy from time to time. If we make changes to this Policy, we will post the amended version on the web, and in other locations as may be required.

Rights of California Workers under the CCPA

If you are a California Worker, you have the following rights with respect to the Personal Information TIPTOP RESTORATION INC. holds about you:

• You have the right to request that we report to you how we collect, use, transfer, or sell your Personal Information.
• You have the right to request that we delete your Personal Information.
• You have the right to opt out of the sale of your Personal Information. (Please note, however, that TIPTOP RESTORATION INC. does not currently sell any Personal Information.)
• You have the right to not receive discriminatory treatment for exercising any of these rights.

In making your request, you must:

Provide us with sufficient information that allows us to verify that you are the person for whom we collected Personal Information or an authorized representative of that person;

Describe your request with sufficient detail that allows us to understand the request.

We may need to contact you in order to clarify your request, confirm your identity, or collect more information in order to verify and respond to your request. If we are unable to verify your identity, TIPTOP RESTORATION INC. will not disclose any specific pieces of Personal Information to you and will inform you that we cannot verify your identity. In the event your request is denied in whole or in part, we will inform you of the reason for such denial.

Disclaimer

Maintaining the security of your Personal Information is of utmost concern to TIPTOP RESTORATION INC. TIPTOP RESTORATION INC. uses reasonable security measures to protect Personal Information from unauthorized access. However, no system can be absolutely secure. Consequently, you should not transmit through email or our website any health information or other information that you consider sensitive. TIPTOP RESTORATION INC. cannot warrant the security of any data transmitted via email or through our website, and you do so at your own risk.

4. How To Contact Us

If you have any questions regarding this HR Privacy Notice and Policy or our privacy practices or want to exercise your privacy rights under this Policy, please leave us a message to contact us at the number 1-800-788-1196 or email info@tiptoprestoration.com.