Aptima, Inc.

Privacy Notice for California Personnel (this “Privacy Notice”).

This Privacy Notice relates to information collected online and offline by Aptima, Inc. (“Aptima” “we” or “us” or “our”) from or about you solely in your capacity as a Aptima employee (each, an “Employee”), as an independent contractor who is a natural person and has been engaged by Aptima (each, a “Contractor”), or as an applicant for employment with Aptima as an Employee or engagement by Aptima as a Contractor (each, an “Applicant”). This Privacy Notice has been prepared for your information and understanding of the policies, philosophies, and practices of Aptima with respect to your Personal Data and shall be effective from and after August 24, 2026 (the “Effective Date”). As used herein, “you” and “your” means any Employee, Contractor, or Applicant. This Privacy Notice will apply only to the extent that we are regulated as a business under the CCPA and only if you are a California resident. Our main office address is 8 Cabot Rd, STE 4000 Woburn, MA 01801. 


Please contact privacy@aptima.com if you have any questions or concerns related to this Privacy Notice. Upon request, alternative formats of this Privacy Notice are available to individuals with a disability. 


If you provide us with information of an emergency contact, spouse, partner, dependent, or any other third party, it is your responsibility to obtain consent from that third party prior to sharing their information with us. If you are an Applicant, if you intend to provide us with information of a reference or any other third party as part of your application process, it is your responsibility to obtain consent from that third party prior to sharing their information with us.


1. Definitions


1.1. “CCPA” means the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (as may be further amended from time to time and collectively with any regulations promulgated thereunder).


1.2. “Personal Data” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, to the extent you are a California resident. Personal Data does not include deidentified or aggregated information, Publicly Available Information or lawfully obtained, truthful information that is a matter of public concern, or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA.


1.3. “Processing” (including grammatically inflected forms thereof) means any operation or set of operations which is performed on data or on sets of data, whether or not by automated means, including without limitation collection, recording, organization, structuring, storage, adaptation or alteration, access, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion, erasure or destruction.


1.4. “Publicly Available Information” means information that is lawfully made available from federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public by you or from widely distributed media, or information made available by a person to whom you have disclosed the information if you have not restricted the information to a specific audience. 


1.5. “Sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to a third party for monetary or other valuable consideration. 


1.6. “Sensitive Personal Data” means: (1) Personal Data that reveals (A) your social security, driver’s license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) your precise geolocation; (D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of your mail, email, and text messages, unless we are the intended recipient of the communication; (F) your genetic data; and (2)(A) Personal Data consisting of biometric information processed for the purpose of uniquely identifying you; (B) Personal Data collected and analyzed concerning your health; or (C) Personal Data collected and analyzed concerning your sex life or sexual orientation.


1.7. “Share” (including any grammatically inflected forms thereof) means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions with a third party for cross-context behavioral advertising for our benefit in which no money is exchanged.


Please note that the terms “Selling” and “Sharing” do not include (i) disclosing Personal Data to a third party at your direction, (ii) where you intentionally interact with one or more third parties, or (iii) transfers of your Personal Data to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Aptima, provided that information is used or shared consistent with the CCPA.


To the extent we consider Deidentified Data outside the scope of the CCPA because it is not identifiable, then, to the extent required by the CCPA, Aptima hereby publicly commits to process Deidentified Data in its possession only in a de-identified fashion and not attempt to re-identify such Deidentified Data. “Deidentified Data” means data that cannot reasonably be used to infer information about, and that cannot reasonably be linked to, an identified or identifiable California resident.


2. Personal Data Aptima Collects: We may collect, store, and use the following types of Personal Data about you:

   

• name;

• phone number;

• address;

• email address;

• password (until it is reset after onboarding);

• date of birth;

• social security number;

• driver’s license;

• passport;

• signature;

• background check information;

• health insurance information; 

• information relating to medical condition, or physical or mental disability;

• beneficiary or dependent information;

• emergency contact information;

• financial information (including bank account information);

• tax filing documents, including W-2, W-9, and W-4 information;

• employment verification reports;

• employment history;

• education;

• marital status;

• military status;

• citizenship;

• gender;

• sexual orientation;

• race;

• ethnicity;

• rate of pay and any other compensation paid;

• starting date of employment or contract engagement;

• resume;

• cover letter;

• job or contract applications, and/or other forms of employment or contract engagement inquiries submitted to us;

• performance evaluations;

• waivers and other employment or contractual engagement agreements;

• termination notices;

• documents related to discipline;

• audio and visual recordings, including of interviews, webinars, and/or trainings; 

• documentation of purchases and other expense reimbursement information; 

• Personal Data created, sent, received, or stored within our electronic resources including but not limited to telephone, email (including personal email using a private email account), messaging tools, voicemail, and other communications; and

• Internet and network activity information such as IP address, browsing history, and search history.

• Fingerprints (for security clearance applications).

• City/state level geolocation

• Transcripts (for tuition reimbursement).

   

With respect to Employees, Applicants, and Contractors, we may obtain the above information from you, from third-party sources (including recruiters, former employers, and background check service providers), and/or from publicly available sources, such as social media sites, including LinkedIn.


Our collection, storage, use, and Processing of the foregoing types of Personal Data is required in order to facilitate the Employment Relationship (as defined below) or Contractor Relationship (as defined below) or, in the case of Applicants, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor (as applicable).


3. Use of Personal Data


3.1. In General: We Process Personal Data for the following business or commercial purposes: (i) in the case of Employees, to facilitate, administer and carry out the employer-employee relationship between you and Aptima (including, without limitation, staffing of projects, verifying eligibility for employment, evaluating eligibility for prospective future positions, benefits administration and payroll and human resources functions, and serving as a reference for prospective employees, the “Employment Relationship”), (ii) in the case of Contractors, to facilitate the business relationship between you and Aptima, including to facilitate your provision of services to Aptima and Aptima’s payment to you in consideration for such services, in each case in accordance with the terms and conditions of your agreement with Aptima (the “Contractor Relationship”), and (iii) in the case of Applicants, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor (as applicable). In addition, we may Process certain Personal Data for the protection of Aptima’s rights and the rights of third parties.


3.2. Sensitive Personal Data: Please note that we use or disclose your Sensitive Personal Data, provided that we only use or disclose your Sensitive Personal Data for the purposes specified in Section 7027(m) of the CCPA regulations, and we only collect or process Sensitive Personal Data without the purpose of inferring characteristics about you.


3.3. Sharing and Sales: In the preceding twelve (12) months, Aptima has not Shared or Sold, nor does it or will it Share or Sell, your Personal Data.


4. Disclosures of Personal Data for a Business or Commercial Purpose: Aptima may disclose your Personal Data described above to the following categories of third parties for the business or commercial purposes described below.


4.1. Aptima Customers, Prospective Customers: Aptima may disclose the Personal Data of Employees and/or Contractors to Aptima’s customers (in connection with Aptima’s provision of services to customers) and/or prospective customers (in connection with Aptima’s responses to requests for proposals issued by prospective customers or Aptima’s business development efforts with respect to prospective customers).


4.2. Laws and Legal Rights: Aptima may disclose your Personal Data if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose Personal Data in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our employees, users, Aptima’s intellectual property, or the general public.


4.3. Outside Contractors: We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to our business, including the Employment Relationship or Contractor Relationship, such as facilitating payroll or other payment or (in the case of Employees only) administering benefits, or (in the case of Applicants) facilitating the application process, or (in the case of Employees, Contractors, and Applicants) data storage and hosting providers. In the course of providing products or services to us, these Outside Contractors may have access to your Personal Data. We use reasonable efforts intended to ensure that these Outside Contractors are capable of protecting the security of your Personal Data.


4.4. Sale of Business: We reserve the right to transfer Personal Data to a third party in connection with a sale, merger, or other transfer of all or substantially all of the assets of Aptima or any of its Corporate Affiliates (as defined below), or that portion of Aptima or any of its Corporate Affiliates to which the Employment Relationship or Contractor Relationship relates, or in connection with a strategic investment by a third party in Aptima, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization, or similar proceeding.


4.5. Corporate Affiliates: We may disclose your Personal Data to our Corporate Affiliates. “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Aptima, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise. 

4.6. Professional Advisors: We may provide your Personal Data to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.


4.7. Benefits Providers: We may provide your Personal Data to benefits providers where necessary in the course of the services that they render to us or to you.


5. Your Rights and Choices: The CCPA provides you with specific rights regarding your Personal Data. This Section 5 describes your rights and explains how to exercise those rights.


5.1. Access to Specific Information and Data Portability Rights: You may have the right to request that Aptima disclose certain information to you about our collection and use of your Personal Data over the past twelve (12) months or such other period required by the CCPA. Once we receive and confirm your verifiable request (in the manner described in Section 5.4 below), to the extent required by the CCPA, we will disclose to you:

5.1.1.The categories of Personal Data we collected about you.

5.1.2.The categories of sources for the Personal Data we collected about you.

5.1.3.Our business or commercial purpose for collecting that Personal Data.

5.1.4.The categories of third parties to whom we disclose that Personal Data.

5.1.5.The specific pieces of Personal Data we collected about you (also called a data portability request).

5.1.6.If we disclosed your Personal Data for a business or commercial purpose, a list disclosing disclosures for a business or commercial purpose, identifying the categories of recipients to whom such Personal Data was disclosed and the Personal Data categories that each category of recipient obtained. 


5.2. Deletion Request Rights: You have the right to request that Aptima delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you or your authorized agent (in each case if you are a California resident) in the manner described in Section 5.4 below (“verifiable request”), we will delete (and notify our service providers and/or contractors to delete, unless this proves impossible or involves disproportionate effort) your Personal Data from our records, unless an exception applies or retention of your Personal Data is otherwise permitted by the CCPA. We may deny your deletion request if retaining the information is reasonably necessary for us or our service provider(s) and/or contractor(s) to:

5.2.1.Complete the transaction for which we collected the Personal Data, provide a product or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

5.2.2.Help to ensure security and integrity to the extent the use of your Personal Data is reasonably necessary and proportionate for those purposes.

5.2.3.Debug to identify and repair errors that impair existing intended functionality.

5.2.4.Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.

5.2.5.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

5.2.6.Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete the research, if you have provided informed consent.

5.2.7.Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.

5.2.8.Comply with a legal obligation.


5.3. Correction Request Rights: You have the right to request that we correct inaccurate Personal Data about you that we maintain, taking into account the nature of the Personal Data and the purposes of the Processing of the Personal Data. If we receive a verifiable request from you to correct inaccurate Personal Data, we will use commercially reasonable efforts to correct such inaccurate Personal Data as directed by you, pursuant to Section 1798.130 of the CCPA and regulations adopted pursuant to the CCPA.


5.4. Exercising Access, Data Portability, Correction, and Deletion Rights

5.4.1.To exercise the access, data portability, correction, and deletion rights, please submit a verifiable request to us by either: (1) calling us at 866-317-8288; (2) visiting https://aptima.com/opt-out-preferences/; or (3) contacting us at privacy@aptima.com. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable request related to your Personal Data. Someone legally authorized to act on your behalf (such as an authorized agent) may make a verifiable request on your behalf, provided that you have duly authorized that person or entity to make such a verifiable request on your behalf and provided that that person or entity can provide verification of their authority to make such a request on your behalf where required. You may also make a verifiable request on behalf of your minor child. You may make a verifiable request for access or data portability no more than twice within a twelve (12) month period. 

5.4.2.The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable request does not require you to create an account with us. We will only use Personal Data provided for the purposes of verification of a consumer request to verify the requestor’s identity or authority to make the request. In the event you make a request under this Section 5, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating video conferencing or telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you. 

5.4.3.We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.


5.5. Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

5.5.1.Denying you goods or services;

5.5.2.Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

5.5.3.Providing you a different level or quality of goods or services;

5.5.4.Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or

5.5.5.Retaliating against an employee, applicant for employment, or independent contractor, as defined in subparagraph (A) of paragraph (2) of subdivision (m) of Section 1798.145 of the CCPA for exercising their rights under the CCPA.


6. Personal Data Retention: We will only retain your Personal Data (including Sensitive Personal Data) for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of that Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.


7. Overview of Our Privacy Practices in the Preceding 12 Months

In particular, with respect to Employees, Applicants, and Contractors, we have collected the following categories of Personal Data from California residents or households within the last twelve (12) months and, in connection therewith, we may collect the following categories of Personal Data from California residents or households:

      

 

CCPA CATEGORIES OF PERSONAL INFORMATION

A. IDENTIFIERS

CCPA Information Collected:
Name; phone number; address; email address; password (until it is reset after onboarding); date of birth; social security number; driver’s license; passport; signature; health insurance information; beneficiary or dependent information; emergency contact information; military status; and marital status.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • If you are an Applicant, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor.
  • Protection of Aptima’s rights and the rights of third parties.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.
  • From third-party sources, including recruiters and background check providers.

B. PERSONAL INFORMATION DESCRIBED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(e))

CCPA Information Collected:
Name; phone number; address; social security number; driver’s license; passport; signature; health insurance information; education; employment history; financial information (including bank account information); and information relating to medical condition, or physical or mental disability.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • If you are an Applicant, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.
  • From third-party sources, including recruiters and background check providers.

C. PROTECTED CLASSIFICATION CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LAW

CCPA Information Collected:
Gender; sexual orientation; race; citizenship; ethnicity; information relating to medical condition, or physical or mental disability; marital status; and military status.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • If you are an Applicant, in connection with reviewing materials you provide to us as part of your application to enter into an Employment Relationship with us or for us to engage you as a Contractor.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.

D. COMMERCIAL INFORMATION

CCPA Information Collected:
Documentation of purchases and other expense reimbursement information.

Purposes for Which We Collect or Use CCPA Information:
To facilitate expense reimbursement.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.

E. BIOMETRIC INFORMATION

CCPA Information Collected:
Fingerprints (for security clearance applications).

Purposes for Which We Collect or Use CCPA Information:
To facilitate the Employment Relationship between you and Aptima.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.

F. INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION

CCPA Information Collected:
CCPA information created, sent, received, or stored within our electronic resources, including but not limited to telephone, email (including personal email using a private email account), messaging tools, voicemail, and other communications; Internet and network activity information such as IP address, browsing history, and search history.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • Protection of Aptima’s rights and the rights of third parties.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Automatically collected by us or on our behalf.

G. GEOLOCATION DATA

CCPA Information Collected:
City/state level geolocation.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • Protection of Aptima’s rights and the rights of third parties.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Automatically collected by us or on our behalf.

H. AUDIO, ELECTRONIC, VISUAL, THERMAL, OLFACTORY, OR SIMILAR INFORMATION

CCPA Information Collected:
Audio and visual recordings, including of interviews, webinars, and/or trainings.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • If you are an Applicant, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.
  • Automatically collected by us or on our behalf.

I. PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION

CCPA Information Collected:
Background check information; employment verification reports; employment history; education; rate of pay and any other compensation paid; starting date of employment or contract engagement; resume; cover letter; job or contract applications, and/or other forms of employment or contract engagement inquiries submitted to us; performance evaluations; tax filing documents, including W-2, W-9, and W-4 information; waivers and other employment or contractual engagement agreements; termination notices; and documents related to discipline.

Purposes for Which We Collect or Use CCPA Information:

  • If you are an Employee, to facilitate the Employment Relationship between you and Aptima.
  • If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.
  • If you are an Applicant, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.
  • From third-party sources, including recruiters and background check providers.

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))

CCPA Information Collected:
Transcripts (for tuition reimbursement).

Purposes for Which We Collect or Use CCPA Information:
To facilitate the Employment Relationship between you and Aptima.

Categories of Third Parties and Business or Commercial Purposes for Disclosure:
In each case for the business or commercial purpose described above: Outside Contractors, as further described in Section 4.3 above.

Categories of Sources:

  • Submitted to us by you.

  

 

SENSITIVE CCPA INFORMATION

A. Government identifiers (social security, driver’s license, state identification card, or passport number)


Sensitive CCPA information collected:
Social security number; driver’s license; and passport.


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.

If you are an Applicant, to evaluate whether or not to enter into an Employment Relationship with you or to engage you as a Contractor.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Submitted to us by you.


B. Complete account access credentials (account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account)


Sensitive CCPA information collected:
Email address and password (until it is reset after hiring).


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Automatically generated by us or on our behalf.


C. Racial or ethnic origin


Sensitive CCPA information collected:
Race or ethnicity.


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.

If you are an Applicant, in connection with reviewing materials you provide to us as part of your application to enter into an Employment Relationship with us or for us to engage you as a Contractor.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Submitted to us by you.


D. Mail, email, or text messages contents not directed to us


Sensitive CCPA information collected:
CCPA information created, sent, received, or stored within our electronic resources, including but not limited to telephone, email (including personal email using a private email account), messaging tools, voicemail, and other communications; Internet and network activity information such as IP address, browsing history, and search history.


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.

Protection of Aptima’s rights and the rights of third parties.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Automatically collected by us or on our behalf.


E. Biometric information processed for the purpose of uniquely identifying you


Sensitive CCPA information collected:
Fingerprints (for security clearance applications).


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
To facilitate the Employment Relationship between you and Aptima.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:


In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Submitted to us by you.


F. Health information


Sensitive CCPA information collected:
Health insurance information, information relating to medical condition, or physical or mental disability.


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.

If you are an Applicant, in connection with reviewing materials you provide to us as part of your application to enter into an Employment Relationship with us or for us to engage you as a Contractor.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Submitted to us by you.


G. Information concerning sex life or sexual orientation


Sensitive CCPA information collected:
Sexual orientation.


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.

If you are an Applicant, in connection with reviewing materials you provide to us as part of your application to enter into an Employment Relationship with us or for us to engage you as a Contractor.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Section 4.3 above.


Categories of sources from which sensitive CCPA information is collected:
Submitted to us by you.


H. CCPA information of California residents if we have actual knowledge such individuals are under the age of 16


Sensitive CCPA information collected:
Beneficiary or dependent information, as well as personal information of our interns, in each case to the extent relating to a California resident who we actually know is under the age of 16.


Purposes (including business or commercial purposes) for which we collect or use sensitive CCPA information:
If you are an Employee, to facilitate the Employment Relationship between you and Aptima.

If you are a Contractor, to facilitate the Contractor Relationship between you and Aptima.

If you are an Applicant, in connection with reviewing materials you provide to us as part of your application to enter into an Employment Relationship with us or for us to engage you as a Contractor.


Categories of third parties to whom we have disclosed sensitive CCPA information for a business purpose and the business or commercial purposes for disclosing sensitive CCPA information:
In each case for the business or commercial purpose as set out above:

Outside Contractors, as further described in Article I Section 4.2 above.


Categories of sources from which sensitive CCPA information is collected:
Submitted to us by you.

  

8. Miscellaneous: In this Privacy Notice, unless a clear contrary intention appears: (i) where not inconsistent with the context, words used in the present tense include the future tense and vice versa and words in the plural number include the singular number and vice versa; (ii) the titles and subtitles used in this Privacy Notice are used for convenience only and are not to be considered in construing or interpreting this Privacy Notice; (iii) “hereunder,” “hereof,” “hereto,” and words of similar import shall be deemed references to this Privacy Notice as a whole and not to any particular Section or Subsection of this Privacy Notice; (iv) “including” (and with correlative meaning, “include”) means including without limiting the generality of any description preceding such term; and (v) where not inconsistent with the context, the word “or” is not exclusive.