California Consumer Privacy Act Policy (CCPA)

CALIFORNIA PRIVACY NOTICE AND NOTICE AT COLLECTION FOR JOB APPLICANTS

Effective Date: 4/15/2025

Solugenix Corporation (“Solugenix,” “we,” or “us”), is committed to protecting your privacy. This Privacy Notice and Notice at Collection (“Privacy Notice” or “Notice”) explains what personal information we collect from California job applicants and candidates for employment (“you”), why we collect it, how we use and share it, and the rights you may have relating to your personal information under the California Consumer Privacy Act of 2018, as amended from time to time, and its implementing regulations (collectively, the “CCPA”). 

This Notice applies only to job applicants and candidates for employment residing in, domiciled in, or living in California for other than temporary or transitory purposes. This Notice does not apply to employees or any interactions job applicants may have with us when acting in an individual or household capacity. To learn more about our handling of the information we collect from individuals acting in an individual or household capacity, or when visiting our website, please visit our Privacy Policy at: https://about.solugenix.com/cookies-privacy-policy. This Notice applies only to the extent we direct the purposes and means of the processing of California applicants’ personal information and otherwise qualify as a business under the CCPA.

Job applicants with disabilities may access this Notice in an alternative format by contacting DataPrivacyTeam@Solugenix.com

All processing of personal information about you by Solugenix in your capacity as a job applicant or candidate for employment is carried out in accordance with this Notice. Certain terms used in this Privacy Notice have the meanings given to them in the CCPA.

I.    Personal Information We Collect
Depending on your interactions with us, we may not have collected each of these categories of personal information about you. However, we may collect (and may have collected during the 12-month period prior to the effective date of this Privacy Notice) the following categories of personal information about California job applicants: 

1. Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifiers, such as device identifiers, internet protocol addresses, cookie identifiers, beacon identifiers, pixel tags or mobile ad identifiers or similar technology, or other forms of persistent or probabilistic identifiers that can be used to identify a particular person or device, email address, account name, or other similar identifiers.
2. Categories of personal information described in California Civil Code § 1798.80, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education information, employment information, employment history, or medical information.
3. Demographic data, including protected classifications under California or federal law, such as gender, sex, race, age (40 and over), ethnic origin, religion, marital status, sexual orientation, medical condition, disability, citizenship status, nationality, and veteran or military status.
4. Professional and employment-related information, such as work history, resume, cover letter, job application materials, academic and professional qualifications, educational records, references, and interview notes, job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
5. Education information, such as student records or other 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).
6. Internet or other electronic network activity information, such as search history, browsing history, login information, and IP addresses.
7. Geolocation data, such as time and approximate physical location related to use of an internet website, application, device, or physical access to an office location.
8. Sensory or surveillance information, such as health related temperature checks, call monitoring and video surveillance.
9. Inferences and profiles based on other personal information, such as information about your behavior and aptitudes for hiring purposes.

Other information you choose to provide, such as career planning, hobbies and interests. 
We do not collect or process “sensitive personal information” (as defined under the CCPA) for the purpose of inferring characteristics about you.

By providing us with personal information, you agree that you are authorized to provide us with such information. Where the information you are providing pertains to someone else (e.g., a family member or agent), you acknowledge that you are required to inform them of the contents of this Privacy Notice. 

II.    Sources of Personal Information 
During the 12-month period prior to the effective date of this Privacy Notice, Solugenix may have collected or received personal information:

1. Directly from job applicants, including where job applicants provide us with information relating to dependents, family members, and emergency contacts;
2. Automatically and indirectly from job applications, such as though logging and analytics tools, cookies, pixel tags, and other similar technologies on our websites and information technology systems and equipment; and
3. From third parties, such as job applicant references and our service providers and business partners involved in our recruitment application and evaluation processes.

III.    Retention of Personal Information 
We retain personal information for as long as necessary to carry out the processing activities described in this Privacy Notice, including but not limited to for our hiring and recruitment purposes, compliance with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies, and protecting our, our employees’, and our business partners’ and clients’ rights, property, or safety and the rights, property and safety of others. We may retain personal information for a longer period of time if a longer retention period is required or permitted by applicable law, as well as our records retention requirements and policies. For example, we may retain your personal information for longer periods of time, such as to carry out our human resources operations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. In specific circumstances, we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

IV.    Purposes for Using, Disclosing, and Otherwise Processing Personal Information 
Solugenix will use (and may have used during the 12-month period prior to the effective date of this Privacy Notice) your personal information for the purposes of carrying out recruitment, hiring, and retention purposes, including the uses described below. 
Administer the employment relationship.

• Comply with all applicable laws, regulations, rules, and requests of law enforcement and/or other governmental agencies.
• Recruit and evaluate job applicants and candidates for employment.
• Enable applicants and candidates to search and apply for jobs.  
• Conduct background checks.
• Manage the application, employment, or contract relationship with us, including without limitation for:
  • Onboarding processes;
  • Contacting and communicating with you;
  • Fitness for duty examinations;
  • Other human resources purposes; and
  • Other business purposes.
• Respond to communications.
• Manage, monitor, and secure our facilities, equipment, and systems.
• Conduct internal audits and workplace investigations.
• Investigate potential breaches of and enforce compliance with our policies and procedures.
• Engage in corporate transactions requiring review of applicant records.
• Maintain commercial insurance policies and coverages.
• Perform workforce analytics, data analytics, and benchmarking.
• Administer and maintain our operations, including for safety or security purposes.
• Manage litigation and/or other legal disputes or inquiries.
• Optimize and improve our services. 
• Exercise or defend our legal rights and the rights of our employees, affiliates, clients, contractors, and agents.
• Protect our, our employees’, and our business partners’ and clients’ rights, property, or safety, and the rights, property, and safety of others.

V.    Disclosures of Personal Information for a Business Purpose 

We do not: 

• Sell job applicants’ personal information;
• Share or disclose job applicants’ personal information for cross-context behavioral advertising; 
• Use job applicants’ sensitive personal information for purposes other than those allowed by the CCPA as set out in Cal. Code Regs. tit. 11 § 7027(m);  or
• Sell or share the personal information of job applicants under 16 years of age as those terms are defined under the CCPA.

We generally disclose, and in the preceding 12 months we may have disclosed, the categories of personal information listed above in Personal Information We Collect to the following categories of entities for business or commercial purposes as described in Purposes for Using, Disclosing, and Otherwise Processing Personal Information, above:

1. To our subsidiaries and affiliates;
2. To our service providers,  such as IT operating system and platform vendors, human capital SaaS solutions, security vendors, monitoring and data analytics providers, benefits providers, auditors, accountants, outside legal counsel, professional advisors, contractors, suppliers, designated agents, and other professional services companies, and;
3. To other third parties, such as regulatory authorities or other third parties in response to legal process or other legal reporting requirements; and to potential buyers (and their agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our stock or assets (including in the event of a reorganization, dissolution or liquidation); trade union representatives (if applicable); and other similar third parties where disclosure is required for an ordinary business purpose in connection with our provision of services.

VI.    Confidentiality and Protection of Your Personal Information 
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we take measures to limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access. Although we use appropriate security measures once we have received your personal data, the transmission of information over the internet is never completely secure. 

VII.    California Consumer Privacy Rights and Choices 
The CCPA provides you with specific rights regarding your personal information. This section describes those rights and explains how to exercise them. 

• Know and Access: You have the right to request, twice in a 12-month period, that we disclose the personal information we have 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 we disclose personal information, and the specific pieces of personal information we have collected about you. 
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate. 
• Deletion: You have the right to request that we delete certain personal information we have collected about you, subject to certain exceptions.
• Portability: You have the right of portability, or the right to have us transfer your personal information to other persons or entities upon your request.
• Non-Discrimination: You have the right to not be discriminated against for exercising your privacy rights.
• Rights related to Automated Decisionmaking:  We do not currently use automated decisionmaking technologies to make decisions that could produce a legal effect on our applicants; however, in the event we do this you may ask us to ensure that, when we are evaluating you, where prohibited by law we will not base any decisions solely on an automated process, and we will provide any legally required information to you regarding the role of automated decision making in the process. In the event we implement automated decision-making technology, you may obtain information regarding this process by contacting us in writing as set forth in the Contact section below.

How to Submit a Request
If you wish to opt out of our recruitment database in accordance with the California Consumer Privacy Act (CCPA), you may do so at any time by clicking here to submit your request.

Verifying Requests
To help protect your privacy and maintain security, we will take steps to verify your identity before granting access to your personal information or complying with your request. If you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request and provide appropriate proof of identity. For requests to know or delete information about a child under the age of 13, we accept requests for information regarding minors under the age of 13 if we can determine that such requests were submitted by a parent or guardian.

Authorized agents may initiate a request on your behalf using the same methods described above. Authorized agents will be required to provide proof of their authorization, and we may also require that you directly verify your identity and the authority of the authorized agent. You may also provide us with a signed and dated power of attorney naming the authorized agent as your representative.

Responding to Requests
Within 10 days of receiving your request to delete, request to correct, or request to know, we will confirm receipt of the request and provide information about how we will process the request.  Generally, we will respond to your request within 45 days.  If we need more time to respond, we will provide you with notice and an explanation of the reason we need more time to respond.  

We may deny your request if we cannot verify your identity or are legally permitted to deny the request, such as if doing so proves impossible or would involve disproportionate effort. If we deny your request, we will explain the basis for the denial, provide or delete any personal information that is not subject to the denial, and refrain from using the personal information retained for any purpose other than as permitted by the denial. We will maintain a record of your request and our response for 24 months. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request if the request is manifestly unfounded, excessive, or repetitive.

VIII.    Changes to this Notice 
We may update this Notice to reflect the changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the Effective Date above. We encourage you to periodically review this Notice for the latest information on our privacy practices.

IX.    Contact
If you have any questions or concerns regarding this Privacy Notice or our collection of your personal information, please contact us at DataPrivacyTeam@Solugenix.com.