Effective Date: March 3, 2026

 

Market Resource Partners, LLC operating as pharosIQ and its affiliates (“Company,” “we,” or “us”) respect the privacy of our current and past employees and job applicants. This California Employee and Applicant Privacy Notice (the “Privacy Notice”) applies solely to job applicants and current and past employees (including, where applicable, directors, and contractors) who reside in California. Provisions in this Privacy notice dealing with individuals employed with pharosIQ are not applicable until they begin working for us.

This Privacy Notice describes the categories of Personal Information we collect from and about job applicants and current and past employees in connection with their employment relationship with us, where we collect it from, why we collect it, how we use it, how we protect it, and when we disclose it.

Please note that the pharosIQ Privacy Policy, rather than this Privacy Notice, applies to your use of pharosIQ’s publicly available websites.

What is Personal Information?

“Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Except as provided under applicable laws, Personal Information does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual. Personal Information also excludes certain types of information that are subject to other federal and state data privacy laws. This includes certain laws related to your health and benefits.

Categories of Personal Information We Collect

We may collect the following categories of Personal Information when you apply for a job with pharosIQ or during the course of your employment:

Category	Data Element Collected
Identifiers	Full name, nickname, suffixes, alias, work and personal postal addresses, work and personal email addresses, phone numbers, employee identification number, IP address, social security number, other government-issued identification numbers, driver’s license, passports and visas, emergency contact information, and date of birth.
Employment and Benefits Records	·     Physical characteristics or description and photograph. ·     Information related to employment benefits we provide eligible employees and their eligible beneficiaries, such as identification data and other relevant information, health information (including vaccination status), vacation, leaves of absence, accommodations information and beneficiaries. ·     Banking information for direct deposit purposes. ·     Information related to your desire to attend an event, food preferences, and travel arrangements. ·     Information regarding vehicles for parking purposes. ·     Information necessary to maintain visitor logs and screening.
Demographic Information and Protected Classification Characteristics Under State or Federal Law	Age, race, color, national origin, citizenship, religion or creed, ethnicity, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy or childbirth and related medical conditions), veteran or military status.
Internet or Other Similar Network Activity	·      Internet protocol (IP) address, network and electronic communication information about your computer or wireless device (such as email, electronic calendars and other software), browser type and version, time zone setting and location, online trackers, browser plug-in types and versions, operating system and platform, username/login identification, passwords, answers to security questions, browsing history, and search history. ·     Information required to access pharosIQ’s applications, networks, systems, services and pharosIQ issued electronic devices (such as computers, laptops, tablets and cell phones) (“IT Infrastructure”), and email communications as well as information that you store, send, submit, or receive through pharosIQ’s IT Infrastructure.
Geolocation Information	City, state, zip code, and country (based on IP Address).
Sensory Information	·     Your photograph, audio or video recordings of you, or similar information, including if you take customer service calls. ·     We utilize cameras which record activities in our facilities to protect the safety of our employees, visitors, and facilities.
Employment and Professional Experience	·     Current or past job history or performance evaluations. ·     Disciplinary actions and grievances. ·     Training and development plans. ·     Previous employer information (company name, location and references) ·     Military service information. ·     Language skills and other skill categories. ·     Licenses, certifications, awards, memberships and participation in trade associations or professional organizations. ·     National ID/passport and other official documentation in support of authentication or eligibility for employment (e.g., Form I-9).
Education Information	Information about your educational background, such as schools attended, degrees earned, continuing education information, and certificates.
Application Information	·     Information you provide to us in support of an application and/or the application and recruitment process, including information provided in interviews and in resumes. ·     Details of the type of employment you are looking for, current and/or desired salary, other terms relating to compensation and benefits packages, and job preferences. ·     Reference information and/or information received from background checks which you authorize (as applicable), including information provided by third parties. ·     Information related to any previous applications you may have submitted to pharosIQ and/or any previous employment history with pharosIQ.

Sources of the Information We Collect and Purposes for Which We Collect it

We may collect Personal Information about you from the following sources:

• Information You Provide to Us Directly. We may collect Personal Information directly from you, for example, when you apply for a job, complete payroll and benefits forms, participate in benefits programs, or when you otherwise communicate with us.
• Information We Collect Electronically. We may collect Personal Information electronically when you use our company equipment, vehicles, or the IT Infrastructure or visit our websites.
• Information We Collect from Third Parties. We may collect Personal Information from third parties, including our affiliates, business partners, service providers (such as recruiting agencies, background check service providers, and networks), professional advisors, and social media platforms. We may collect commercially available demographic and background information, employee preference data, and/or third party business contact information collected from other sources. We may also collect Personal Information from operating systems and platform providers, internet service providers and IT service providers.

How We Use Your Personal Information

We use the Personal Information we collect from or about you as a job applicant or current or past employee for the following purposes:

Purpose	Description
Managing the Hiring Process	We may use your Personal information in the hiring process to conduct interviews and, if you are offered a position, to perform background and reference checks (with your consent).
Communicating With You	We may use your Personal information to provide information to you, respond to your questions, notify you of changes to your compensation and benefits, or notify you of emergencies.
Managing the Onboarding Process	Upon being hired by pharosIQ, we will collect Personal Information when you complete new hire paperwork to assist us in administering human resources, salary and benefits and to assist us with complying with governmental and legal requirements.
Administering Compensation and Benefits Programs	We will use the Personal Information you provide to process payroll, pay taxes, help employees address employment-related tax issues, administer benefits, and handle work-related expense reimbursements. We may also use this Personal information to manage requests for accommodations and administer employee claims, such as workers’ compensation or unemployment benefits.
Managing Recruiting	We may use Personal Information to communicate with you regarding the recruiting process, learn where you heard about pharosIQ, and evaluate and improve our recruiting process.
Managing Performance	PharosIQ collects Personal Information to assess your job performance, assist in career development, conduct pay and grading reviews, and to handle any employment-related disputes. We may also use Personal Information to respond to violations of company policies and to gather information for disciplinary actions. We use Personal Information for purposes of internal performance improvement and disciplinary procedures to respond to complaints.
Providing Education and Professional Development	We may use your Personal Information to assist with education, training, and professional development.
Maintaining Records	We may use Personal Information to comply with applicable legally required or industry-standard business and employment recordkeeping requirements and to respond to governmental requests for information.
Maintaining Health and Safety	We may use your Personal Information to protect your health and safety or the health and safety of others, including through the use of technology to allow contact tracing in the event of a communicable disease outbreak, epidemic or pandemic. We may also use this information to respond to an employee-related emergency.
Maintaining Security	We may use your Personal Information to monitor the use of the IT Infrastructure, to conduct internal audits or investigations, and to assist in managing our safety and security protocols for our employees, visitors, and facilities. We may also use such information to protect pharosIQ or third parties against illegal activity and misconduct such as fraud, deceptive practices, and data security incidents. We use this information to offer, operate, maintain, deliver, troubleshoot, and update our IT Infrastructure and the other platforms, programs, networks, and systems used by pharosIQ in the course of its business.
Conducting Regular Business Operations	We may use your Personal Information in connection with our regular business operations, which may include, without limitation, engaging in research; designing and developing products, services, and technologies; analyzing costs and expenses, including, without limitation, salary, travel, and expense data; providing information to customers and business partners for work purposes, such as business contact information; conducting employee engagement surveys and charity campaigns; responding to questions or concerns from stakeholders; and business planning and due diligence, including planning for or executing mergers, acquisitions, and divestitures.
Compliance with Applicable Laws, Regulations, and Internal Policies and Procedures	We may use your Personal Information to comply with our obligations under applicable laws, regulations and internal policies and procedures. This may include tracking demographic information to confirm compliance with applicable legal requirements; processing information relating to your health in order to comply with our obligations under applicable employment safety and health laws; verification of employment; tax obligations; insurance coverage and unemployment; performing audits and compliance reviews to ensure compliance with applicable policies, regulations, and laws; conducting and managing internal and external investigations, including legal, corporate, ethics and compliance, regulatory compliance reviews and any resulting disclosures to government agencies; prosecuting and defending claims in litigation, arbitration, administrative, or regulatory proceedings, including but not limited to pre-dispute activity, evidence collection, discovery, litigation holds and e-discovery efforts; responding to law enforcement and other government inquiries; protecting intellectual property rights; and other practices as required or expressly authorized by applicable law or regulation.
Business Transactions	We may use your Personal Information in connection with certain business transactions, such as in connection with performing due diligence activities in a potential business transaction; in the situation where the company is sold or is the subject of a merger or similar transaction, we will disclose and transfer Personal Information on a permanent basis in light of the change of control; or in the case of a bankruptcy or corporate reorganization.

We will not use your Personal Information for marketing purposes or other purposes incompatible with the employment-related purposes for which we collected it without your prior consent.

Processing of Sensitive Data

We may request certain sensitive Personal Information, such as race, ethnicity, marital status, religion, trade association or disability status. Requests to provide sensitive information will be voluntary, except where required by law. Collection and processing of sensitive information is necessary for pharosIQ to carry out its legal obligations, including those as an employer. Your sensitive Personal Information will not be used for any other purpose other than for your employment with pharosIQ, in accordance with this Statement, or with your consent.

Information About Dependents/Contacts

If you provide us with Personal Information about members of your family, dependents or beneficiaries (e.g., for emergency contact or benefits administration purposes), it is your responsibility to inform them of their rights with respect to such information. You also are responsible for obtaining the consent of these individuals (unless you can provide such consent on their behalf) to the processing of that Personal Information for the purposes set out in this Privacy Notice.

How Long We Keep Your Personal Information

We retain Personal Information only as long as we have a legitimate business purpose to keep it or as required by law. These purposes may include retaining Personal Information in order to:

• complete the transaction for which the Personal Information was collected;
• continue our ongoing business relationship with you;
• ensure the security and integrity of our Sites, services, and Operations; and
• satisfy any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for individual categories of Personal Information we collect, we consider the nature and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process that Personal Information and whether we can fulfill those purposes through other means; and applicable legal, regulatory, tax, accounting, reporting or other requirements.

Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. We will not attempt to re-identify information once it has been de-identified.

We securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.

Disclosing Personal Information

We may disclose Personal Information we collect about you when requested or consented to by you or to the following categories of third parties for the purposes described in this Privacy Notice:

 

To Whom We Disclose Personal Information	Purpose for Disclosure	Category
Employees with a legitimate and tailored need to know	·       Processing Applications ·       Processing Benefits and Pay ·       Legal Purposes and Protection of Rights ·       Other business purposes	·       Identifiers ·       Protected Classification information ·       Geolocation information ·       Employment Information ·       Education Information ·       Audio recordings
Service Providers	·       Processing Applications ·       Conducting Interviews ·       Processing Benefits and Pay ·       Legal Purposes and Protection of Rights ·       Other business purposes	·       Identifiers ·       Protected Classification information ·       Geolocation information ·       Employment Information ·       Education Information ·       Sensory Information
Professional Advisors	·       Legal Purposes and Protection of Rights ·       Other business purposes	·       Identifiers ·       Protected Classification information ·       Employment Information ·       Education Information ·       Sensory Information
Government Agencies and law enforcement	·       Legal Purposes and Protection of Rights ·       If we suspect you have broken laws in the course of your employment.	·       Identifiers ·       Protected Classification information ·       Geolocation information ·       Employment Information ·       Education Information ·       Sensory Information
Parties to Business Transactions	If we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company, or if we undergo liquidation or bankruptcy proceedings, we may share your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.	·       Identifiers ·       Protected Classification information ·       Geolocation information ·       Employment Information ·       Education Information ·       Sensory Information

We will not disclose your Personal Information for marketing purposes or other purposes incompatible with the employment-related purposes for which we collected it unless we first provide you with the choice to opt-out. We will not use your choice to restrict your employment opportunities or take punitive action against you.

Your Rights and Choices

The CCPA provides certain rights to California residents. Subject to exceptions permitted by applicable laws and verification of your identity, if you live in California, you may exercise the following rights with regard to your Personal Information. Capitalized terms in this Section that are not defined elsewhere in this Privacy Policy have the definitions set forth in the CCPA.

The sections below describe your CCPA rights and explain how to exercise those rights.

Right to Know

You have a right to request that we disclose certain information about you and our collection of your Personal Information over the last 12 months. Once we receive your request and confirm your identity, 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 that Personal Information;
• The categories of third parties with whom we share that Personal Information; and
• The specific pieces of Personal Information we collected about you.

Right to Delete

Except in certain cases where the CCPA does not require us to do so or provides an exception, you have the right to request that pharosIQ delete any of your Personal Information that we collected from you and retain. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies, the CCPA does not require us to do so, or we are otherwise prohibited from doing so by law or regulation.

Exceptions: In accordance with the CCPA, we may deny your deletion request under certain circumstances. If we deny your request, we will explain the reason for the denial.

Right to Correct

You have the right to request that we correct inaccurate Personal Information that we collect about you. If we receive a verifiable request, we will consider it, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. We may deny your request if we are unable to verify your identity, if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances. We may request that you provide us with documentation that is relevant to your request.

Please note, we may choose to delete the contested personal information as an alternative to correcting it if doing so would not negatively impact you or you consent to our deletion.

Exercising Your Rights

To exercise your rights described above, please submit a verifiable request to us by contacting us at:

Market Resource Partners, LLC operating as pharosIQ

Attn: Privacy Department

1818 Market Street, 37^th Floor

Philadelphia, PA 19103

Email: privacy@pharosIQ.com

Who Can Make a Request

If you are a California resident, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. You may also make a request on behalf of your minor child. You may only make such a request twice within a 12-month period.

You have a right to submit requests to exercise your rights under the CCPA through an agent. We may deny a request from an agent if we do not have proof that they are authorized by you to act on your behalf.

Verifying Your Request

For us to process your request, you must provide:

 

• Information sufficient to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• A request with sufficient detail to allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Response Timing and Format

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (an additional 45 days up to a total of 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will 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.

Any disclosures we provide will only cover the 12-month period preceding the date we receive your request. If applicable, the response we provide will also explain the reasons we cannot comply with a request.

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

You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA.

We Do Not Sell or Share

We do not sell or share the Personal Information we collect from or about employees or job applicants.

Changes To This Privacy Notice

We may make changes to this Privacy Notice from time to time, in our sole discretion. We will provide you notice of material changes to this Privacy Notice.

Contact Information

If you have any questions or comments about this notice, the ways in which pharosIQ collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Market Resource Partners, LLC operating as pharosIQ

Attn: Privacy Department

1818 Market Street, 37^th Floor

Philadelphia, PA 19103

Email: privacy@pharosIQ.com