PRIVACY NOTICE AND POLICY FOR CALIFORNIA APPLICANTS AND EMPLOYEES

LAST UPDATED: September 10, 2026

This PRIVACY NOTICE AND POLICY FOR CALIFORNIA APPLICANTS AND EMPLOYEES contains VALLEY IRON, INC..’s policy and privacy notice and disclosure to applicants and employees who reside in the State of California (“you”). We adopt this policy and notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect 

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We collect, use, and disclose personal information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. In particular, we will collect or have collected categories of personal information from you for the following business purposes as follows:

  

Personal   Information Category

Business   Purpose

 

Identifiers, such as your full name, contact   information, gender, date of birth, signature, Social Security number,   driver's license or state identification numbers, and similar information for   your dependents and beneficiaries.

· Recruit and process employment applications, including   verifying eligibility for employment and conducting background and related   checks

· Conduct employee onboarding

· Maintain and administer payroll and employee benefit   plans, including enrollment and claims handling

· Maintain personnel records and complying with record   retention requirements

· Provide employees with human resources management   services and employee data maintenance and support services

· Communicate with employees and their emergency contacts   and plan beneficiaries

· Comply with applicable state and federal labor,   employment, tax benefits, workers' compensation, disability, equal employment   opportunity, workplace safety, and related laws

 

California Customer Records employment   and personal information, such as your name,   signature, Social Security number, physical characteristics or description,   photograph, address, telephone number, passport number, driver’s license or   state identification card number, insurance policy number, education, current   employment, employment history, membership in professional organizations,   licenses and certifications, bank account number, credit card number, debit   card number.

· Recruit, onboard, and process employment applications;   administer payroll, direct deposit, benefits enrollment, and insurance   programs; maintain personnel records; comply with applicable federal and   state law; and exercise or defend the legal rights of the Company and its   employees, customers, contractors, and agents.

 

Protected classification   characteristics under California or federal law, such as age (40 years or older), race,   color, 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, reproductive health decision-making,   military and veteran status, or genetic information (including familial   genetic information).

· Comply with federal and state equal employment   opportunity laws

· Perform workforce analytics, data analytics, and   benchmarking

· Conduct internal audits, grievances, and suspected   violations of Company policy 

· Exercise or defend the legal rights of the Company and   its employees, customers, contractors, and agents

 

Biometric information, such as fingerprints, keystroke, or other   physical patterns, and certain wellness metrics.

· [If applicable: Delete if not used] Collect fingerprints   or other biometric identifiers for   timekeeping, access control, or criminal background check purposes.

· Administer and design health wellness programs

· Exercise or defend the legal rights of the Company and   its employees, customers, contractors, and agents

 

Internet or other similar network   activity information, including all   activity on the Company's information systems (such as internet browsing   history, search history, intranet activity, email communications, social   media postings, stored documents and emails, usernames, and passwords) and   all activity on communications systems (such as phone calls, call logs,   voicemails, text messages, chat logs, app use, mobile browsing and search   history, mobile email communications, and other information regarding an   employee's use of company-issued devices).

· Facilitate the efficient and secure use of Company   information systems

· Ensure compliance with Company information systems   policies and procedures.

· Comply with applicable state and federal laws

· Prevent unauthorized access to, use, or disclosure or   removal of the Company's property, records, data, and information

· Enhance employee productivity

· Conduct internal audits and investigate complaints,   grievances, and suspected violations of Company policy

· Exercise or defend the legal rights of the Company and   its employees, customers, contractors, and agents

 

Geolocation data, such as the time and physical location   related to use of an internet website, application, or device, GPS location   data from mobile devices of employees who participate in our vehicle   reimbursement program; and GPS for drivers.

· Improve safety of employees, customers, and the public   regarding use of the Company property and equipment

· Prevent unauthorized access, use, or loss of the Company   property

· Improve efficiency, logistics, and supply chain   management

· Ensure employee productivity and adherence to the   Company's policies

· Conduct internal audits and investigate complaints,   grievances, and suspected violations of the Company's policy

 

Sensory and surveillance data, such as call monitoring, video surveillance   in common areas, and outward facing dash cams.

· Comply with   applicable state and federal laws, including on workplace health and safety

· Prevent unauthorized access, use, or loss of the Company   property

· Ensure workplace safety and security of employees,   customers, and the public

· Conduct investigations of workplace incidents and   suspected violations of Company policy

· Improve customer service

· Exercise or defend the legal rights of the Company and   its employees, customers, contractors, and agents

 

Professional or employment-related   information, such as employment   application information (work history, academic and professional   qualifications, educational records, references, and interview notes,   background check, drug testing results, work authorization, performance and   disciplinary records, salary, bonus, commission, and other similar   compensation data, benefit plan enrollment, participation, and claims   information, leave of absence information including religious, military and   family obligations, health data concerning employee and their family members.

· Recruit and process employment applications, including   verifying eligibility for employment, background checks, and onboarding

· Design and administer employee benefit plans and   programs, including for leaves of absence.

· Maintain personnel records and comply with record   retention requirements.

· Communicate with employees and their emergency contacts   and plan beneficiaries.

· Comply with applicable state and federal labor,   employment, tax, benefits, workers' compensation, disability, equal   employment opportunity, workplace safety, and related laws.

· Prevent unauthorized access to or use of the Company's   property, including its information systems, electronic devices, network, and   data.

· Ensure employee productivity and adherence to the Company   policies.

· Conduct internal audits and investigate complaints,   grievances, and suspected violations of the Company policy.

· Evaluate and provide useful feedback about job   performance, facilitate better working relationships, and for employee   professional development

· Exercise or defend the legal rights of the Company and   its employees, customers, contractors, and agents

 

Non-public education information, such as education records, degrees and   vocational certifications obtained, report cards, and transcripts.

· Evaluate an individual's appropriateness for hire, or   promotion or transfer to a new position at the Company

 

Inferences drawn from other personal   information to create a profile or summary, for example, an individual's preferences,   abilities, aptitudes, and characteristics

· Engage in human capital analytics, including to identify   correlations about individuals and job success, analyze data to improve   retention and productivity, and analyze employee preferences to inform human   resources policies and procedures

· Conduct applicant reference checks to assist in hiring   decisions

 

Sensitive personal   information, such as Social   Security and government identification numbers, financial account   information, precise geolocation, racial or ethnic origin, religious beliefs,   genetic information, biometric information used for identification, health information,   including information derived from drug or alcohol testing and biological   specimens such as blood or urine where collected for employment-related   testing, physical ability, agility, fitness-for-duty, and other job-related   testing or assessment results and other sensitive personal information as defined by applicable law.

· Recruit, evaluate, and process applicants for employment,   including determining whether an applicant satisfies job-related   qualifications and physical requirements. 

· Conduct employee onboarding and verify identity and   authorization to work. 

· Administer payroll, tax withholding and reporting, direct   deposit, expense reimbursement, and employee benefit plans. 

· Administer leaves of absence, disability accommodations,   the interactive process, workers’ compensation, and return-to-work and   fitness-for-duty processes. 

· Conduct lawful drug and alcohol testing, physical   ability, agility, fitness-for-duty, functional-capacity, and other   job-related testing or assessments. 

· Determine whether an applicant or employee can safely and   effectively perform the essential functions of a position, with or without   reasonable accommodation. 

· Comply with federal and state equal employment   opportunity, anti-discrimination, disability accommodation, wage and tax,   workplace safety, workers’ compensation, and other employment laws. 

· Monitor and promote workplace health and safety and   prevent injury to employees, customers, and the public. 

· Administer employee identification, security,   access-control, timekeeping, fraud-prevention, and information-security   programs where applicable. 

· Administer vehicle, mileage, travel, and other   reimbursement programs, including use of location information where   reasonably necessary. 

· Maintain personnel, payroll, benefits, medical,   accommodation, safety, and other employment records and comply with   applicable record-retention requirements. 

· Conduct internal audits, workplace investigations, and   investigations of suspected violations of Company policies or applicable law.   

· Exercise, establish, or defend the legal rights and   claims of the Company and its employees, customers, contractors, and agents.

Unless otherwise indicated, each category of personal information listed above is also collected, used, and disclosed as necessary to: comply with applicable federal, state, and local law; maintain the security and integrity of Company systems, property, and data; prevent unauthorized access, loss, or misuse; conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy; respond to law enforcement requests and legal process; and establish, exercise, or defend the legal rights and claims of the Company and its employees, customers, contractors, and agents.

We retain each category of personal information for as long as reasonably necessary and proportionate to achieve the disclosed purposes, including for the duration of the employment or applicant relationship and thereafter as necessary to comply with applicable legal, operational, contractual, and record-retention requirements, resolve disputes, enforce agreements, and establish, exercise, or defend legal claims. Retention periods vary depending upon the category of information and the purpose for which it is collected.

Personal information does not include:

• Publicly available      information from government records.
• De-identified or      aggregated consumer information.
• Information      excluded from the CCPA's scope, like:
  • 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) or       clinical trial 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.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you.      For example, from documents beginning from the job application process,      on-boarding documents, and documents necessary for eligibility and      participation in employment benefits.
• Indirectly from      our service providers or their agents. For example, through information we      collect from our service providers in the course of receiving services      from them – such as employment agencies, on-line job resources (including Paylocity.com),      or background check companies.
• Directly and      indirectly from activity on our website (valleyironc.com).. For example,      from submissions through our website portal or website usage details are collected      automatically.

If you applied for a position with the Company through a third-party job platform such as Paylocity, Indeed, or Zip Recruiter, that platform may collect personal information from you and share it with us to process your application. We encourage you to review the platform’s own privacy policy to understand its data practices, which were disclosed to you before submitting your application and which are separate from the Company’s policy.

Use of Personal Information

In addition to the specific business purposes above, we may use, disclose, or share the personal information we collect for one or more of the following business purposes:

· Comply with all applicable laws and regulations.

· Recruit and evaluate job applicants and candidates for employment.

· Manage your employment relationship with us, including for:

o onboarding processes;

o timekeeping, payroll, and expense report administration;

o employee benefits administration;

o employee training and development requirements;

o the creation, maintenance, and security of your online employee accounts;

o reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;

o workers' compensation claims management;

o employee job performance, including goals and performance reviews, promotions, discipline, and termination; 

o other human resources purposes; and

· Manage and monitor employee access to company facilities, equipment, and systems.

· Conduct internal audits and workplace investigations.

· Investigate and enforce compliance with and potential breaches of Company policies and procedures.

· Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.

· Maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.

· Perform workforce analytics, data analytics, and benchmarking.

· Administer and maintain the Company's operations, including for safety purposes.

· Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents. 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Automated Decision-making Technology 

The Company may use automated decision-making technology ("ADMT"), including software, algorithms, or artificial intelligence tools, in connection with employment-related activities. If the Company uses ADMT to make a significant decision concerning an applicant or employee, including a decision concerning employment opportunities or compensation, the Company will provide any Pre-use Notice, right to opt out or appeal to a human reviewer, right to access information concerning the use of ADMT, and other rights required by the CCPA and applicable regulations. Where required, the Company will provide a separate or supplemental notice describing the particular ADMT, the purpose for which it is used, and the applicable rights before the technology is used.

The Company evaluates processing activities as required by applicable privacy law, including conducting privacy risk assessments where required.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When required by the CCPA, we enter into contracts with service providers, contractors, and third parties that contain the protections and restrictions required by applicable law.

We may disclose the following categories of personal information for a business purpose:

· Identifiers.

· California Customer Records personal information categories.

· Protected classification characteristics under California or federal law.

· Professional or employment-related information.

· Biometric information.*

· Internet or other similar network activity information.

· Geolocation data.

· Sensory and surveillance data.

· Non-public education information.

· Inferences drawn from personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Third parties to      whom you or your agents authorize us to disclose your personal      information.

We will not knowingly sell (as defined by CCPA) the personal information, including any sensitive personal information, we collect about our employees or applicants for employment or share it with third parties for cross-context behavioral advertising. We do not knowingly sell or share personal information about consumers under age 16. We use and disclose sensitive personal information only for purposes permitted under the CCPA and its regulations and do not use or disclose sensitive personal information for purposes that would require us to provide a right to limit its use or disclosure.

Your Rights and Choices

As a California resident, you have certain rights under the CCPA with respect to your personal information. This section describes those rights and explains how to exercise them.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information concerning our collection, use, and disclosure of your personal information, including information collected during the period required by the CCPA, which in some circumstances may extend beyond the 12 months preceding your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of      personal information we collected about you.
• The categories of      sources for the personal information we collected about you.
• Our business or      commercial purpose for collecting or sharing that personal information.
• The categories of      third parties with whom we share that personal information.
• The specific      pieces of personal information we collected about you (also called a data      portability request).
• If applicable,      information concerning categories of personal information sold, shared, or      disclosed for a business purpose.

Correction Rights

You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes for which we process it. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information, unless an exception applies.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny or limit a deletion request to the extent permitted or required by the CCPA or other applicable law, including where retention is reasonably necessary to administer the employment relationship, comply with legal obligations, establish or defend legal claims, maintain security and integrity, or accomplish other purposes permitted by law.

Exercising Access, Correction, Data Portability, and Deletion Rights

To exercise the access, correction, data portability, and deletion rights described above, please submit a verifiable request to us by any of the following methods:

• Calling Human      Resources at _ HR      Line (559) 475-5945_________
• Emailing Human      Resources at _HR@valleyiron.com___________
• Mailing Human      Resources at _P.O. Box 12024 Fresno, CA 93776____

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient      information that allows us to reasonably verify you are the person about      whom we collected personal information or an authorized representative.
• Describe your      request with sufficient detail that allows us to properly understand,      evaluate, and respond to it.

Response Timing and Format

We will confirm receipt of a verifiable consumer request within ten (10) business days. We will respond to a verifiable consumer request within 45 days of its receipt, as required by applicable law.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. The period covered by our response will be determined in accordance with the CCPA and applicable regulations, including any right to request information beyond the 12-month period preceding the request.  We will deliver our written response by mail or electronically.  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 information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you because you exercise your rights under the CCPA.

Changes to Our Privacy Policy and Notice

This policy was last updated on September 10, 2026. We reserve the right to amend this privacy policy and notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email, U.S. Mail, providing a hyperlink, or posting.

To view our full privacy policy to consumers, visit www.valleyiron.com . 

To view our applicant/employee privacy policy and notice, visit https://recruiting.paylocity.com/recruiting/jobs/All/d23368d3-093f-45ea-b2d0-2ab8b5fc7fd0/Valley-Iron-Inc

Contact Information

If you have any questions or comments about this policy, this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, or if you need to access this Policy and Notice in an alternative format due to having a disability, please do not hesitate to contact us at:

• Calling Human      Resources at _HR Line (559)475-5945_________________
• Emailing Human      Resources at _HR@Valleyiron.com______
• Mailing Human      Resources at _P.O. Box 12024 Fresno, CA 93776______________