APPLICANT NOTICE | California Consumer Privacy Rights

Effective: January 1, 2023

SkyGroup Investments, LLC (“iFLY,” “we,” “us,” “our”) provides this California Applicant Privacy Notice (“Applicant Notice”) to explain our practices regarding the Collection, use, and disclosure of Personal Information of California job applicants, candidates, and other individuals who provide Personal Information through our job application process (collectively, “Applicants”), including through our careers website. This Applicant Notice explains what Personal Information we Collect about California Applicants, why we Collect it, how we use and disclose it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as amended (the “CCPA”). Capitalized terms defined in the CCPA that are used in this Applicant Notice shall have the same meaning as in the CCPA.

If you interact with iFLY as a consumer, you can find our California Consumer Privacy Notice here.

As used in this Applicant Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Unless otherwise noted the disclosures contained within this Applicant Notice cover our activities in the prior twelve (12) months from the Effective Date as well as our current practices.

I. How and Why We Collect Your Personal Information

We may Collect, use, and disclose Personal Information for Business Purposes consistent with applicable laws as identified below. Where iFLY discloses applicable Personal Information to recipients, such as our Service Providers, it does so for the same Business Purposes described below. These examples may vary depending on the nature of your interactions with us.

II. Sources of Personal Information

We may Collect the Personal Information identified above from the following sources. Whether we Collected information from a specific source depends on the nature of your interaction with us:

• Directly from you when you apply for a job, when you create an account, and throughout your interactions with us, including through company forms.
• Automatically when you use our website or access our facilities.
• From Service Providers and references, such as consumer reporting agencies, former employers, or references.
• Created by us, such as interview notes gathered from information we Collect.

III. Disclosures of California Applicant Personal Information

We may Sell or Share the below categories of Personal Information with third parties for cross-context behavioral advertising. We offer you the ability to opt-out of these disclosures as set forth in the “Opt-Out” section below.

• Identifiers – for advertising purposes with advertisers and analytics providers.
• Internet or other electronic network activity information – for advertising purposes and analytics providers.
• Geolocation data – for advertising purposes and analytics providers

We do not have actual knowledge that we Sell or Share the Personal Information of consumers under 16 years of age.

We disclose the Personal Information described in this Applicant Notice to Service Providers acting on our behalf that help us run our business and manage our human resources activities. We have also disclosed, or may disclose in the future, the Personal Information described in this Applicant Notice in other circumstances when required to or permitted by law. These circumstances include:

• to communicate with you;
• for pre-employment screening purposes, such as background checks;
• disclosures required or permitted by law to defend against legal claims;
• to law enforcement agencies, courts, regulatory agencies and others when the disclosure is required or permitted by law, including to comply with valid legal process; and
• as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets.

IV. How Long We Keep Applicant Personal Information

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Applicant Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we Collected the information;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was Collected;
• The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• We are otherwise required or permitted to keep your information by applicable laws or regulations.
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Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

V. Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request by email to ccpa@iflyworld.com or call us at 1-888-675-0188. Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to verify your identity in accordance with the law. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have Collected about you, which includes:

• The categories of Personal Information we have Collected about you;
• The categories of sources from which the Personal Information was Collected;
• Our Business or Commercial purposes for Collecting or disclosing Personal Information;
• The categories of recipients to which we disclose Personal Information;
• The categories of Personal Information that we disclosed for a Business Purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information; and
• The specific pieces of Personal Information we have Collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we Collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt-out of the “Sale” or “Sharing” of Your Personal Information. California applicants have the right to opt-out of the “Sale” or “Sharing” of their Personal Information in the context of cookies or other tracking technologies. You can learn how to exercise choices regarding these technologies by following the instructions in the Opt-Out Rights section below. To opt out of types of cookie-based Sales or Sharing, please click the “Do Not Sell or Share My Personal Information” link in the footer of our website.

You may also opt out of the Sale or Sharing of your Personal Information via cookies or tracking technologies through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an optout preference signal, you will need to turn it on for each browser and each device you use.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Applicant Sensitive Personal Information for purposes in which the right to limit, use, and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as an Applicant.

VI. How to Contact Us

If you have any questions about how iFLY handles your Personal Information or if you need to access this Applicant Notice in an alternative format or language, please contact our Human Resources Department at:

Phone: 1-888-675-0188
Email: ccpa@iflyworld.com