Privacy Policy

Effective: January 1, 2025

At Affiliates Management Company (“AMC”, “we”, “our” or “us”) we respect your concerns about privacy and value our relationship with you, thus we created this Privacy Policy (“Policy”) to demonstrate our commitment to you. This Policy explains what information we gather and how we use it as related to our website, www.affiliatesmgt.com, including its subdomains, subdirectories, and related domains directed to www.affiliatesmgt.com (collectively, the “Website” or “Sites”). By using the Website, you acknowledge that your personal data will be processed in accordance with this Policy. Please also see our Terms of Use which are incorporated into this Policy. Further, if you submit an application through the Acquire Talent Management platform linked from the Website, you also accept If you submit an application through our Website, you also accept https://acquiretm.com/privacy-policies/privacy-policy-applicant/ and https://acquiretm.com/terms-of-use/ the Acquire Privacy Policy (https://acquiretm.com/privacy-policies/privacy-policy-applicant/) and Terms of Use (https://acquiretm.com/terms-of-use/).

We may revise and update this Policy from time to time in our sole discretion. All changes are effective immediately when we post them to the Website, and apply to all access to and use of the Website thereafter. Your continued use of the Website following the posting of revisions means you acknowledge the changes. You are expected to check this page from time to time so you are aware of any changes.

This Policy applies to information we collect:

• On this Website;
• In email, text, and other electronic messages between you and this Website;
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website; or
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does not apply to information collected by:

• AMC offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries); or
• Any third party (not affiliated with our Website or services offered through our Website), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Data protection is a high priority for AMC. The use of the Website pages of AMC is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our Website, processing of personal data could become necessary.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject is in line with the California Consumer Privacy Act (CCPA), and in accordance with other state-specific data protection regulations applicable to AMC. By means of this Policy, we like to inform the public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this Policy, of the rights to which they are entitled.

Data Security

We and our service providers have implemented measures designed to secure your personal information from unintentional loss and from unauthorized access, use, alteration, and disclosure. We believe we have taken reasonable precautions necessary to maintain security for this Website.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a user name, password or any other piece of information for access to certain parts of our Website, you are responsible for keeping this information confidential. You also acknowledge that your account is personal to you and agree not to provide any other person with access to this Website or portions of it using your user name, password or other security information. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information.

Ultimately, the transmission of information via the Internet is not completely secure. Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of information transmitted to or stored on our Website. Any transmission or storage of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide an option to submit a job application.
• To provide you with information, products, or services you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To monitor and identify potential fraudulent or suspicious activity.
• To allow you to participate in interactive features on our Website.
• To contact you when we believe there is an issue that needs to be communicated, such as site outages or planned maintenance.
• To use for marketing and user-evaluation purposes, including marketing of services by our affiliates. • In any other way we may describe when you provide the information.
• For any other purpose with your consent or such other legal basis as may be relevant, but, where appropriate, only after notifying you in advance with any information that we are required to provide to you.

Cookies

The Website uses cookies, which are text files stored in a computer system via an Internet browser. Many websites use cookies. Many cookies contain a cookie ID, which is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited sites and servers to differentiate the individual browser of the data subject from other web browsers that contain other cookies. A specific Internet browser can be recognized and identified using cookie IDs.

Through the use of cookies, AMC can provide users of this Website with user-friendly services that would not be possible without the cookie setting.

By means of a cookie, information and offers on our Website can be optimized with the specific user in mind. Cookies allow us to recognize our Website users. The purpose of this recognition is to make it easier for users to use our Website.

The data subject may, at any time, prevent the setting of cookies through our Website by use of the corresponding setting of the Internet browser used, and may permanently deny the setting of cookies. Cookies that are already set may be deleted at any time via an Internet browser or other software programs. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our Website may be entirely usable. For more information about the cookies set by our websites, please see the Cookie Policy.

Collection of general data and information

Our Website collects general data and information when a data subject calls up the Website. This general data and information are stored in the server log files. Collected information may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using this general data and information, AMC does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Website correctly, (2) optimize the content of our Website as well as its advertisement(s), (3) ensure the long-term viability of our information technology systems and Website technology, and (4) provide information necessary for investigation, civil claims and/or criminal prosecution in case of a cyber-attack. Therefore, AMC analyzes anonymously collected data and information statistically, with the aim of increasing our data protection and data security, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

Disclosure of Your Information

We may use and disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy:

• To our affiliates to market their products or services to you if you have consented to these marketing disclosures and to receive marketing emails.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal Commented [KM1]: Spinutech - please insert the URL to the Cookie Policy page that was just created. information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, reorganization, dissolution, or other sale or transfer of some or all of AMC's assets, in which personal information held by AMC about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use, any license or other similar agreement between you or your organization and AMC, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AMC or its affiliates, our clients, or others.

Consent to Emails & Text Messages

Our website enables the ability to submit a job profile/application, and in submitting an application you agree that we may use your phone number, email address to contact you via phone, voicemail, email and/or text communications related to the application submitted.

Information for California Residents

Effective: January 1, 2025.

This notice supplements the Privacy Policy and applies only to all visitors, users, and others who reside in the State of California, United States of America (collectively, “consumers”). This notice sets forth the disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”). Terms used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.

Outlined below are the categories of information that we collect from California consumers (in general terms), the sources of the information, the purposes for which the information is used, and the categories of third parties to whom we disclose the information for business purposes (and information on how to opt-out).

The CCPA defines personal information ("Personal Information”) as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

The following are the categories of Personal Information that we have collected from our users over the last 12 months (and examples of the types of information those include), the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, the categories of third parties with whom we disclose the information for a business purpose, and the categories of third parties to whom this type of personal information is sold. Note, we do not sell, and in the past 12 months we have not sold, personal information to any third parties.

The Personal Information we collect about consumers will depend upon how you use our Website or otherwise interact with us. Accordingly, we may not collect all the below information about you. We may also collect and/or use additional types of information after providing notice to you before collection and obtaining your consent (to the extent such notice and consent is required by the CCPA). The following are examples of Personal Information we may collect as categorized by the CCPA:

Category	Examples	Collected
A. Identifiers	Name, physical address, email address; phone number	Yes
B. Personal information categories listed in the CCPA	Name, address, telephone number, email address; password; gender; race/ethnicity; veteran or military status,  Some personal information included in this category may overlap with other categories	Yes
C. Protected classification characteristics under California or US federal law	Race/ethnicity, gender	Yes, as disclosed
D. Commercial information	Product or application interest	Yes
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns	No
F. Internet or other electronic network activity information	Browsing data, web beacon while on the website; IP address, browser type and version used to access the website, cookie information (see our Cookie Policy)	Yes
G. Geolocation data	Physical location or movement	Yes
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No
I. Professional or employment-related information	Professional certifications, work history	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a 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	Yes
K. Inferences drawn from other personal information.	preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes	Yes

Use of Personal Information

Please see the “How We Use Your Information” section to learn more about how we use the information we collect.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Within the last 12 months, we have disclosed Personal Information for our business purposes. To learn more about the categories of third parties with whom we share Personal Information, please see the “Disclosure of Your Information” section.

Your California Privacy Rights

If you are a California consumer, you have certain rights related to your Personal Information, including:

1. The right to know what Personal Information we have collected about you within the last 12 months:
   • the categories of Personal Information we collected about you and the categories of sources from which we collected the Personal Information,
   • the business or commercial purpose for collecting, selling, or sharing Personal Information we collected,
   • the categories of third parties to whom we disclose Personal Information about you, and
   • the specific pieces of Personal Information we collected about you.
2. The right to correct inaccurate Personal Information we collected about you.
3. The right to delete Personal Information that we have collected from you, subject to certain exceptions.
4. The right to opt out of the sale or the sharing of Personal Information.
   • We do not sell Personal Information
5. The right to limit the use or disclosure of your sensitive personal information.
   • We only use sensitive information to the extent you elect to disclose as part of your application. It is disclosed to our application tracking vendor and to our affiliate company with whom your application for employment is directed
6. The right not to receive discriminatory treatment by a business for exercising your CCPA privacy rights, including the right not to be retaliated against for exercising your CCPA rights.

Making a Request

You may make a request to know, correct, or delete by:

• Contacting us at 866.596.3060, or
• Submitting your request at communications@affiliatesmgt.com

When you request access to the Personal Information we have collected or request correction or deletion of your Personal Information, we will provide the requested information within 45 days, subject to verifying as described below. You will be notified within that time period if we need additional time to process your request.

You may only submit a request to know twice within a 12-month period.

Verifying Requests to Access

We will take steps to verify your identity to fulfill your request. We will verify your email address is active and we will take steps to verify the information you provide to us. In order to verify your identity we will request the following pieces of information: your name, email address, and ZIP code.

To safeguard against fraudulent requests, after submitting your request we will take steps to confirm that you want your information deleted.

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent. If we are unable to verify your identity (or the identity of someone submitting a request on your behalf) we will not delete the information.

Deidentified Information

In response to a deletion request, we may erase some information and we may de-identify some information. To de-identify information, we use technical safeguards and business processes that prevent re-identification. Business processes prevent the inadvertent release of de-identified information and no attempt will be made to re-identify information.

Users under the Age of 16

We do not knowingly collect personal information of children under the age of 16.

Information for Residents of Other States

Virginia, Connecticut, Colorado, Delaware, Florida, Indiana, Iowa Montana, Oregon, Tennessee, Texas and Utah provide (now or in the future) their states residents with the right to:

• Confirm whether we process their personal information
• Access and delete certain personal information
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah)
• Data portability
• Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales, or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data

The exact scope of these rights may vary from state to state.

Making a Request

You may make a request to know, correct, or delete by:

1. Contacting us at 866.596.3060, or
2. Submitting you request at communications@affiliatesmgt.com

To appeal our decision regarding your request, or to contact AMC, please use the options listed above.

Changes to this Privacy Policy

We may update or modify this Privacy Policy at our discretion at any time. When we make changes to this Privacy Policy we will post the updated policy online and update the policy’s effective date. Please review this Privacy Policy periodically.

If we are required by applicable law to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law. More Information For more information, you can write to us at Affiliates Management Company, Attn: AMC Marketing, 7745 Office Plaza Drive North, Suite 170, West Des Moines, IA 50266 or call us at 866.596.3060.