Privacy Notice to California Job Applicants, Employees, and Independent Contractors

Effective Date : February 24, 2023

GOLO, LLC (“ GOLO ”, “ we ”, “ our ”, or “ us ”) provides this Privacy Notice for Job Applicants, Employees, and Independent Contractors (“ Notice ”), which supplements the information contained in our general Privacy Policy (available at www.golo.com/pages/privacy-policy, and as updated from time to time, and which is incorporated herein by reference).

This Notice applies only to employees, independent contractors, and applicants for those roles who reside in California (collectively, “ you ” or “ your ”). For all other California residents, the California privacy notice section of our Privacy Policy applies. Any terms used in this Notice (whether or not capitalized) which are defined in the California Consumer Privacy Act of 2018 or its successor, the California Privacy Rights Act of 2020 (“ CCPA/CPRA ”) have the same meaning as in such definitions.

We want you to understand our collection, use, disclosure, and retention of your “Personal Information,” which means 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 consumer or household. You should also review all other agreements or terms that may apply to your relationship with us.

We are committed to protecting your privacy, and we use administrative, technical, and physical safeguards designed to protect your Personal Information from unauthorized access, disclosure, alteration, or loss.

Personal Information We Collect and Purposes for Use

In the previous 12 months, we have collected the categories of Personal Information identified in Table 1 below to administer any relationship you and we have with each other, comply with legal obligations, facilitate communications and efficiency, provide benefits, to ensure the safety of employees, independent contractors, facilities, and property, or for other purposes.

Categories of Personal Information We Collect and Purposes for Use

TABLE 1

Categories of Personal Information	Examples of Data within Category	Purpose for Collection and Use
Identifiers	Name, postal address, internet protocol address, email address	Administer the employee/contractor relationship Comply with legal obligations Facilitate communications and efficiency Provide benefits Ensure the safety of employees, contractors, facilities, and property
Demographic	Birth date, national origin, country of residence	Demographic
Personal information categories listed in the California Customer Records statute	Name, address, telephone number	Administer the employee/contractor relationship Comply with legal obligations Facilitate communications and efficiency Provide benefits Ensure the safety of employees, contractors, facilities, and property
Protected classification characteristics under California or federal law	Age, gender, ethnicity	Administer the employee/contractor relationship Comply with legal obligations Provide benefits
Internet or other similar network activity	Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement	Administer the employee/contractor relationship Facilitate communications and efficiency Provide benefits Ensure the safety of employees, contractors, facilities, and property
Biometric	Fingerprint	To verify authorized access to secured facilities
Professional or employment-related information	Information about previous employment	Administer the employee/contractor relationship Comply with legal obligations Ensure the safety of employees, contractors, facilities, and property
Other	Marital and dependent status Beneficiary and emergency contact information Bank account details and payroll information Wage and benefit information Compensation history Performance information Insurance enrollment information Trade union membership, under some circumstances Start date Employment location Education and training Employment records (including professional memberships, references, work history, and proof of work eligibility) Photograph Other personal details included in a resume or cover letter	Administer the employee/contractor relationship Comply with legal obligations Provide benefits Ensure the safety of employees, contractors, facilities, and property

Please note, however, that the specific pieces of information that we may have collected about any specific individual may differ due to the nature of the individual’s position, role, and benefits. We may have your Personal Information collected by our service providers, including recruiting firms, application processors, background check service providers, and the like.

Purpose for Collection of Personal Information

The purposes for our collection of Personal Information are described in Table 1.

Administer the Employee/Contractor Relationship

We need to keep and process Personal Information for normal employment and independent contractor engagement purposes, including identifiers, personal information, and protected classifications. The Personal Information we hold and process will be used for management and administrative uses and only shared with others who have a need to know such information. We will keep and use it to enable us to run our business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, while you are working for us, and after your employment or engagement has ended. This includes using Personal Information to enable us to comply with any legal requirements associated with an employee or independent contractor relationship, to administer payroll, to provide and manage employee benefits, to provide training, to recruit others, to ensure your health and safety, to comply with an employment or service contract, to demonstrate our commitment to equal employment opportunity and fair employment practices, and to otherwise enable you to perform your professional obligations and responsibilities at our company.

Compliance with Legal Obligations

In certain situations, we may need to collect and process your Personal Information to comply with our legal obligations. These obligations include:

Tracking demographic information to confirm compliance with equal opportunity and non-discrimination policies and requirements;
Processing information relating to your health in order to comply with our obligations under applicable employment and safety and health laws;
Verification of employment;
Tax obligations;
Insurance coverage and unemployment; and/or,
Producing information relevant to any alleged violation of law or in compliance with a subpoena or other valid legal or regulatory request.
Facilitate Communications

We use various tools and platforms that enable you to communicate with other employees and personnel and to access and share work product and other work-related materials more efficiently.

Provide Benefits

We collect Personal Information, such as identifiers, protected classifications, and employment information, as is necessary for benefits administration. When you participate in certain benefits programs (as may be applicable to you), we may also generate a log of your activity, track internet and other network activity, and develop a user profile to provide those programs to you in a manner tailored to your preferences.

All benefits may not be available to all personnel, and we will only collect Personal Information to provide a benefit if you are eligible for and enrolled in that benefit. Employees should take care to read the specific terms applicable to any benefits program to understand the specific pieces of information collected.

Ensure Safety

We collect various categories of Personal Information to ensure the health and safety of its employees, contractors, facilities, and property. Some information, such as identifiers, personal information, protected classifications, and possibly biometrics (e.g., fingerprint, image, etc.) under limited circumstances help verify your identity in specific facilities, as well as help screen for indicators of infectious diseases or vaccination status of those entering facilities. Other categories of information, such as geolocation data and sensory data, may assist us with ensuring the security of people, facilities, and property.

Sharing and Sale of Personal Information

We may share your Personal Information with our service providers in order to fulfill a business purpose for collecting or using that Personal Information.

Retention of Personal Information

Any Personal Information collected by us or our service providers will be retained (i) while considering a candidate for an employment or contractor relationship; (ii) during the period of person’s active employment/engagement; and, (iii) during the post-employment/engagement period as long as retention is reasonably necessary and proportionate to achieve the purposes for which it was collected and not otherwise incompatible with such purposes.

Sensitive Personal Information

Certain categories of Personal Information are deemed “sensitive” under CPRA. We may collect use the categories of “sensitive” Personal Information and for the purposes as described in Table 2 below:

TABLE 2

Category	Examples of PI in the Category	When Collected	Purpose for Use
Identifiers	social security number	Collected by third party after of offer of employment (but not disclosed to us); provided by you to us at start date during onboarding process	To comply with federal filings
Identifiers	driver’s license or state ID number passport number	Provided by you at start date during onboarding process	To comply with federal filings
Characteristics of protected classifications under California or federal law	racial or ethnic origin	Provided by you at start date during onboarding process	To comply with federal filings
	gender, sexual orientation	Provided by you at start date during onboarding process	To provide health benefits
Biometric information based on characteristics	image, fingerprint	Provided by you at start date during onboarding process	To identify a specific person (e.g., ID verification), only for clocking in and security
Financial	bank account numbers	Provided by you at start date during onboarding process	For direct deposit
The contents of an employee’s mail, email, and text messages unless the business is the intended recipient of the communication		When created	To protect the company’s trade secrets and confidential information.

We retain the information in Table 2 during your employment or engagement us and thereafter.

Your Rights

California residents have certain rights regarding their data (subject to certain exceptions as set out in CPRA).For employees, candidates, and independent contractors, these rights are: (a) access a copy of their Personal Information held by us; (b) have inaccuracies in their Personal Information to be corrected; (c) limit our use of sensitive Personal Information we collect to what is necessary to perform the services or provide the goods reasonably expected by an average consumer (for this right, with respect to our relationship with you); (d) request information about the categories of Personal Information we collect and sell and data we share with third parties (we do not sell or share (as those terms are defined in the CPRA) your Personal Information); (e) request that we provide information about the logic behind any automated decision-making and likely outcome of such processes (no such decision-making is done regarding you); (f) transmit your Personal Information to another business; (g) request deletion of their Personal Information held by us (except as permitted in the CPRA or by applicable law or regulation); (h) opt-out of the use of automated decision-making technology, including profiling (we do not do this with your Personal Information); and, (i) opt-out of the sale or sharing of your Personal Information (which we do not do).

Updates to the Notice

This Notice is subject to periodic revision and updated versions are effective when posted. The current version of this Notice will also be posted for employment and independent contractor position candidates, on our website at www.golo.com/pages/ca-employee-privacy-policy For current employees this notice will be distributed by email.

We may be subject to certain laws and regulations relating to privacy and information security in more than one jurisdiction. If any term, covenant, condition, or provision of this Notice is held by a court of competent jurisdiction to be invalid, void, or unenforceable, it is the intent of this Notice that the scope of the rights and obligations of the Notice be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Notice will in no way be affected, impaired, or invalidated as a result.

Contact Us

If you have questions regarding this Notice, please contact GOLO Human Resources at hr@golo.com.

* Disclaimer: Testimonial results were obtained over a period of six months to four years and may not be typical and your results may be more or be less than the averages stated on this website. While some people may experience greater weight loss in the first few weeks the GOLO weight loss system is designed to minimize weight loss to 1 to 2 pounds per week to minimize muscle loss. Expect an average weight loss of 1-2 pounds per week using the GOLO system. The GOLO weight loss system includes the GOLO Diet along with behavior and lifestyle recommendations including a recommendation for moderate exercise. Typically, the testimonials and reviews on this site come from study participants or GOLO customers and members who followed the GOLO For Life Plan and also took the Release supplement. GOLO is not intended to diagnose, treat, cure or prevent any disease and has not been evaluated by the FDA. Consult your doctor before starting GOLO or any weight loss program and before reducing or eliminating any medications. For study summaries and more information and disclosures please review Studies in the Studies page and for additional disclaimers and terms and policies go to the Privacy Policy and Terms page. Release is manufactured in the U.S.A. from both domestic and foreign ingredients.