Privacy Notice for California Applicants and Personnel

Last Updated: March 6, 2026

1. Introduction and Scope

1.1 Purpose of This Notice

This Privacy Notice for California Applicants and Personnel (“Notice”) describes how Optery, Inc. (“Optery,” “we,” “us,” or “our”) collects, uses, discloses, and retains the personal information of California residents in connection with a potential or actual employment or working relationship. This Notice also serves as our notice at collection under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), and as our privacy policy for personnel personal information under California Civil Code Section 1798.130(a)(5).

1.2 Covered Individuals

This Notice applies to California residents in the following categories (collectively, “you” or “your”):

• Current and former employees
• Job applicants and candidates
• Independent contractors
• Officers and directors
• Dependents, emergency contacts, and beneficiaries of the individuals listed above who receive benefits or services through Optery

2. Personal Information We Collect

2.1 Categories of Personal Information

We may collect the following categories of personal information, depending on your role and relationship with Optery:

2.2 Categories of Sensitive Personal Information

We may collect the following categories of sensitive personal information, depending on your role and relationship with Optery:

*Note: Optery does not collect your precise geolocation or neural data.

3. Sources of Personal Information

We collect personal information from the following categories of sources:

• Directly from you. Information you provide during the application process, onboarding, benefits enrollment, and throughout your working relationship with Optery.
• Recruiting platforms. Information received from job boards, recruiting tools, or professional networking services in connection with your candidacy.
• Background check and screening providers. Results of pre-employment or ongoing background checks, to the extent permitted by law.
• Benefits administrators and insurers. Information related to enrollment, claims, or eligibility for benefits programs and workers’ compensation.
• Government agencies. Information obtained from tax authorities, employment eligibility verification systems, or other governmental sources as required by law.
• Publicly available sources. Information from professional networking profiles or other public sources that you have made available.
• Optery systems and devices. Information generated through your use of Optery-provided devices, systems, and applications.

4. Purposes for Collecting and Using Personal Information

We may collect and use personal information for the following business purposes, depending on your role and relationship with Optery:

• Recruiting and hiring. Evaluating applications, conducting interviews, performing background checks, and making hiring decisions.
• Onboarding. Setting up payroll, benefits enrollment, system access, and completing required employment documentation (e.g., I-9, W-4).
• Compensation and payroll. Processing wages, bonuses, commissions, equity awards, tax withholdings, and expense reimbursements.
• Benefits administration. Enrolling Personnel and their dependents in health insurance, retirement plans, equity plans, and other benefit programs; processing claims.
• Performance management. Conducting performance reviews, setting goals, managing promotions, training, and professional development.
• Workplace operations. Communicating with Personnel, managing schedules, coordinating travel, maintaining company directories, and supporting day-to-day operations.
• IT and security. Provisioning and managing devices and system access, maintaining network security, and protecting Optery’s systems and data.
• Legal compliance. Complying with federal, state, and local laws and regulations, including tax, employment, workplace safety, immigration, and equal employment opportunity laws.
• Workplace safety and investigations. Addressing workplace safety concerns, conducting internal investigations, and responding to complaints.
• Corporate transactions. Evaluating or completing mergers, acquisitions, reorganizations, or other corporate transactions involving review of personnel records.
• Legal proceedings. Establishing, exercising, or defending legal claims; responding to subpoenas, court orders, or government requests.
• Insurance. Maintaining commercial insurance policies, including workers’ compensation and liability insurance.

5. Retention of Personal Information

We retain each category of personal information for as long as reasonably necessary to fulfill the purposes described in Section 4, or longer where required by applicable law or regulation, or where necessary to establish, exercise, or defend legal claims.

When personal information is no longer needed for any of these purposes, we will delete or de-identify it in accordance with our data retention policies.

6. Disclosure of Personal Information

6.1 Categories of Personal Information Disclosed for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information to service providers and third parties for business purposes:

6.2 Service Provider Agreements

Each service provider that receives your personal information is contractually obligated to use the information only for the specific business purposes described in its agreement with Optery and to maintain appropriate security measures.

7. Sale and Sharing of Personal Information

Optery does not sell your personal information. Optery does not share your personal information for cross-context behavioral advertising.

8. Use and Disclosure of Sensitive Personal Information

Optery uses and discloses sensitive personal information only for purposes permitted under the CCPA, including:

• Performing services reasonably expected in connection with the employment or working relationship (e.g., payroll, tax reporting, benefits administration, I-9 verification)
• Preventing, detecting, and investigating security incidents
• Ensuring the physical safety of individuals
• Complying with legal obligations

We do not use or disclose sensitive personal information for purposes that would require us to offer you the right to limit such use.

9. Your Privacy Rights Under the CCPA

If you are a California resident, you have the following rights with respect to your personal information:

9.1 Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties to whom we have disclosed your personal information.

9.2 Right to Delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions provided by law.

9.3 Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you.

9.4 Right to Opt-Out of Sale or Sharing. Because Optery does not sell or share personnel personal information, this right does not apply. If our practices change, we will update this Notice and provide a mechanism for you to opt out.

9.5 Right to Limit Use of Sensitive Personal Information. Because Optery uses sensitive personal information only for purposes permitted under the CCPA, this right does not apply. If our practices change, we will update this Notice and provide a mechanism for you to limit such use.

9.6 Right to Non-Retaliation. Optery will not retaliate against you for exercising any of your privacy rights, including by altering your compensation, terms, or conditions of employment.

10. How to Exercise Your Rights

10.1 Submitting a Request

To exercise your rights to know, delete, or correct your personal information, you may submit a request through any of the following methods:

• Email: support@optery.com
• Internal Channels: Contact the business operations department via Slack or Email.
• Mail: Send a written request to Optery, Inc., 2261 Market Street STE 86983, San Francisco, CA 94114.

Please include in your request sufficient information for us to identify you and the specific right you wish to exercise. We will respond to verifiable requests within forty-five (45) calendar days of receipt. If we need additional time, we will notify you of the extension and the reason for it, for up to an additional forty-five (45) calendar days.

10.2 Verification Process

When you submit a request, we will verify your identity by matching identifying information you provide with the personal information we already maintain about you. The level of verification will depend on the type of request and the sensitivity of the information involved. For requests to know specific pieces of personal information, we apply a higher standard of verification. If you submit a request to correct inaccurate personal information, Optery may request that you provide documentation to verify that the information currently on file is indeed inaccurate. We will only use this documentation for the purpose of correction and will delete it as soon as the request has been processed, unless retention is otherwise required by law.

10.3 Authorized Agents

You may designate an authorized agent to submit a request on your behalf. To do so, the authorized agent must provide either a written authorization signed by you demonstrating that the agent has been authorized to act on your behalf or a valid power of attorney pursuant to California Probate Code Sections 4121 to 4130.

We may still require you to verify your identity directly before fulfilling the request.

10.4 Opt-Out Preference Signals

Optery does not sell or share personnel personal information as contemplated by this Notice. If our practices change, we will update this Notice.

11. Contact Information

If you have questions or concerns about this Notice or Optery’s privacy practices, or if you wish to exercise your rights, you may contact our business operations team via our internal communication channels, email us at support@optery.com, or send physical mail to: Optery, Inc., 2261 Market Street STE 86983, San Francisco, CA 94114.

Changes to This Notice. We may update this Notice from time to time. When we do, we will display a “Last Updated” date above and notify you through the methods we normally use to communicate employment-related information.