LAST UPDATED: August 18, 2025

1. INTRODUCTION

   Spectra Logic Corporation and its subsidiaries ("Spectra" or "us", "we" or "our") are committed to protecting the privacy and security of the personal information you provide to us. Please read this Privacy Notice for Employees and Contractors (the "Privacy Notice") to learn how we collect, use, share and protect your personal information when you are employed by Spectra.

   If you are a resident of Australia, you have the right to access and correct your personal information, to be informed about how your data is collected and used, to make complaints about privacy breaches, and to expect your personal information to be handled in accordance with the Australian Privacy Act (the "APA").

   If you are a resident of California, you have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information, pursuant to the California Consumer Privacy Act of 2018 (the "CCPA"). Spectra does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

   If you are a resident of EU, Switzerland or UK, have the right to access, correct, delete, and restrict the processing of your personal data; object to certain uses; receive your data in a portable format; lodge complaints with supervisory authorities; and withdraw consent where processing is based on consent, pursuant to GDPR or FADP, as applicable (collectively, the "GDPR").

2. INFORMATION WE COLLECT ABOUT YOU

   For the purposes of this Privacy Notice, Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Sensitive Personal Information includes anything that reveals an individual's personal information, such as Social Security number, driver's license number, state identification card, passport number, account log-in, password, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. We collect the following types of Personal Information and Sensitive Personal Information:

   Category	Examples	Collected/Purpose
   Personal identifiers	name preferred name postal address unique personal identifier or online identifier Internet Protocol address email address account name Social Security number date of birth other similar identifiers.	YES We use this information to onboard personnel; enroll and administer benefits; enter into contracts; and for general human resources management.
   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	name signature Social Security number address telephone number passport number, driver's license or state identification card number insurance policy number education employment and/or employment history health data for you and your family disability data family-related data including marital status banking, credit card and other financial data.	YES We collect pay information (pay rate, payroll deductions, banking information, direct deposits and credit card information) to pay our personnel and provide expense reimbursements. We collect other information in this category to provide benefits and comply with applicable laws.
   Protected classification characteristics under applicable law	age (40 years or older) race 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). Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.	YES We collect equality and diversity information (minority, veteran and disability status) through voluntary self-disclosure and other means to implement our diversity programs and to comply with applicable laws. We collect health and safety information to maintain a safe workplace; assess your working capacity; administer health and Workers' Compensation programs; and comply with applicable laws. We also collect information necessary for benefits enrollment and administration purposes.
   Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES – Contractors If you are a contractor, we may collect commercial information from or about you in connection with obtaining services from you.
   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, and sleep, health, or exercise data.	YES We may collect fingerprints to ensure that log-ins to our computers and other devices are secure and sleep, health or exercise data in connection with employee wellness programs.
   Internet or other similar network activity.	email, computer, internet, telephone and mobile device usage IP address, log-in information and location information Browsing history, search history or information regarding your interaction with a website, application or advertisement	YES We collect this information to protect Spectra and customer property, equipment and confidential information; monitor personnel performance; and enforce our electronic communications and acceptable use policies.
   Geolocation data.	physical location or movements.	YES We may collect IP addresses.
   Sensory data.	Audio and visual information	YES We may collect your audio and visual information through photographs used for identification purposes and to promote Spectra. We also collect audio and video recordings of company meetings, conference calls and training sessions.
   Professional or employment-related information.	Performance management information, such as employment status (full-time or part-time, regular or temporary), work schedule, job assignments, hours worked, accomplishments and awards Training and development information Performance evaluation information Discipline and counselling information Employment termination information	YES We collect professional and employment-related information to manage our relationship with you.
   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 history education records (such as grades, transcripts and class lists) information included in your resume or cover letter	YES We collect education information in connection with the job promotion process; to evaluation employees for promotions; and to feature employees in marketing materials and on our website.
   Inferences drawn from other personal information.	Profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	YES We may collect inferences drawn from other personal information to manage our relationship with you.
   Personal data about children under the age of 16	Personal Information about employees' dependents under the age of 16	We collect information about your dependents under the age of 16 if you voluntarily provide this information in connection with the enrollment and administration of benefits and for other human resources purposes that involve your dependents.
   Legal and contractual information	Legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise and defend, legal and contractual rights claims.	YES We collect this information to comply with legal and and contractual requirements and to establish, exercise and defend legal and contractual rights and claims.
   Emergency contact information	Name and contact information Relationship to employee	YES We collect this information to contact your designated emergency contact persons if there is an emergency.
   Beneficiary information	name and contact information relationship to the employee birth date Social Security number information necessary to process benefits claims	YES We collect this information to enroll and administer benefits programs for your beneficiaries.

   We do monitor employee use of the Internet to detect access to inappropriate websites or other misuse of the Company's computer network. We also use email filters to block spam and computer viruses. These filters may from time to time block legitimate email messages.

3. SOURCES OF PERSONAL INFORMATION

   We collect Your Information when you apply for a job and complete the employee onboarding process as well as at other times during your employment, including open enrollment for benefits. We collect Your Information because it is necessary for our legitimate business purposes. Your refusal or failure to provide Your Information as requested may disqualify you from employment with Spectra or from receipt or enjoyment of certain company benefits.

   We may also combine personal information collected from other sources with the personal information that you provide to us. For example, we may collect information from:

   • Recruiters
   • Prior employers (e.g., for references)
   • Professional references you provide to us
   • Educational institutions
   • Pre-employment screening services
   • Credentialing and licensing organizations
   • Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter and Facebook)
   • Other sources as directed by you
4. HOW WE USE YOUR PERSONAL INFORMATION

   We use Your Information for the following purposes:

   • Human Resources Management. We collect, store, analyze and share (internally) Your Information to attract, retain and motivate a highly qualified workforce. This includes recruiting, compensation planning, succession planning, reorganization needs, performance assessment, training, employee benefit administration, compliance with applicable legal requirements, and communication with employees and/or their representatives.
   • Conduct background checks (as permitted by applicable law): We use Your Information to conduct reference checks and to evaluate your qualifications and experience. We may also conduct background checks (as authorized by you and permitted by applicable law).
   • Provide immigration support: If applicable and as permitted by applicable law, we may collect Your Information to assist with immigration support, such as applying for visas or work permits.
   • Business Processes and Management. Your Information is used to run our business operations including, for example, scheduling work assignments, managing company assets, reporting and/releasing public data and populating employee directories. Your Information may also be used to comply with government regulation.
   • Safety and Security Management. We use Your Information as appropriate to ensure the safety and protection of employees, assets, resources and communities.
   • Communication and Identification. We use Your Information to identify you and to communicate with you.
   • Record-keeping: We keep records of Your Information as required by law and in accordance with our record retention policies.
   • Meeting legal requirements and enforcing legal terms: We collect and process Your Information for purposes of (a) fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; (b) protecting the rights, property or safety of you, us or another party; (c) enforcing any agreements with you; (d) responding to claims; and (e) resolving disputes. Additionally, we may use Your Information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.
5. DISCLOSURE OF YOUR INFORMATION

   We act to protect Your Information and ensure that unauthorized individuals do not have access to Your Information by using security measures to protect Your Information. We will not knowingly disclose, sell or otherwise distribute Your Information to any third party without your knowledge and, where appropriate, your express written permission, except under the following circumstances.

   However, we may share Your information as necessary for the purposes described in this Privacy Notice, including, for example, with the following parties:

   • Affiliates: We may share Your Information with our affiliates.
   • Legal requests and investigations. We may disclose Your Information when such disclosure is reasonably necessary to (a) prevent fraud; (b) comply with any applicable statute, law, rule or regulation; or (c) comply with a court order.
   • Third-party vendors and service providers. We may, from time to time, outsource services, functions, or operations of our business to third-party service providers. When engaging in such outsourcing, it may be necessary for us to disclose Your Information to those service providers, e.g., a payroll service or a benefits provider. In some cases, the service providers may collect Your Information directly from you on our behalf. We will work with any such providers to restrict how the providers may access, use and disclose Your Information.
   • Business Transfers: During the term of your employment, we may buy other companies, create new subsidiaries or business units or sell part or all of Spectra or its assets. It is likely that some or all of Your Information will be transferred to another company as part of any such the transaction. However, Your Information will remain subject to protection outlined in this Privacy Notice.
   • Protection of Company and Other. We may release Your Information when we believe release is necessary to comply with the law; enforce or apply our policies and other agreements; or protect the rights, property, or safety of Spectra, our employees, or others. This disclosure will never, however, include selling, renting, sharing or otherwise disclosing Your Information for commercial purposes in violation of the commitments set forth in this Privacy Notice.
6. SECURITY OF YOUR PERSONAL INFORMATION

   We employ reasonable security measures and technologies, such as password protection, encryption, etc., to protect the confidentiality of Your Information. Only authorized employees have access to Your Information.

   If you are an employee with such authorization, it is imperative that you take the appropriate safeguards to protect such Information. Paper and other hard copies containing Personal Information, Sensitive Personal Information or any other confidential information should be secured in a locked location when not in use. Computers and other access points should be secured when not in use by logging out or locking. Passwords and user IDs should be guarded and not shared. When no longer necessary for business purposes, paper and hard copies should be immediately destroyed using paper shredders or similar devices. Do not leave copies in unsecured locations waiting to be shredded or otherwise destroyed. Do not make or distribute unauthorized copies of documents or other tangible medium containing personal data. Electronic files containing Personal Information or Sensitive Personal Information should only be stored on secure computers and not copied or otherwise shared with unauthorized individuals within or outside of Spectra.

7. UPDATING AND ACCESSING YOUR PERSONAL INFORMATION

   You must promptly inform us when changes occur in Your Information so that we can maintain accurate information about you. You can access and change most of Your Information through Rippling. You may also contact HR at [email protected] to submit changes. Although you may update or change Your Information, we may maintain Your Personal Information previously submitted in historical archives.

8. RETENTION PERIOD

   We will retain Your Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use Your Information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.

9. CROSS-BORDER DATA TRANSFERS

   If you are an employee who resides outside of the United States, we will transfer your Personal Information to the United States and other jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of protection as your country of residence. We will take reasonable steps to ensure that all entities that have access to your Personal Information protect your Personal Information as described in this Privacy Notice.

10. COMPLIANCE

    Compliance with this Privacy Notice is important to Spectra. Any violation or potential violation of this Privacy Notice should be reported to HR at [email protected] or via the EthicsHotline. The failure by any employee to follow these policies regarding privacy may result in discipline up to and including discharge of the employee. Any questions or suggestions regarding this Privacy Notice may also be directed to [email protected].

11. CHANGES TO THIS PRIVACY NOTICE

    We may update this Privacy Notice from time to time. When we do, we will post the current version on the Spectra1 (UKG), and we will revise the version date located at the top of this page. Any changes become effective when we post the revised Privacy Notice.

12. CONTACT US

    If you have questions or concerns regarding this Privacy Notice or practices, please contact the HR at [email protected] or Legal at [email protected].