Applicant Privacy Policy

Effective Date:  January 1, 2026

This Applicant Privacy Policy (“Applicant Policy” or “Policy”) informs individuals applying for or interested in applying for a role at Cox Enterprises, Inc., Cox Automotive, Inc., Cox Communications, Inc., and their respective affiliates and subsidiaries, (collectively the “Company” or “we” or “us” or “our”) of our practices regarding the collection, use, sale, sharing, and retention of your personal information (“Information Practices”) as a job applicant located in the United States and Canada through our Talent Community and Applicant Tracking System (the “Site”) and other online and in-person methods of collection, including through a recruiter, to facilitate your job application (“Applicant Personal Information”), or otherwise where this Policy is posted.

This Policy applies to information collected from and about individuals applying for or interested in applying for a role at the Company and should be read in association with all other Company policies that may be provided to you as part of the application process or that govern the Company websites, including the Cox Privacy Policy.

Please note that Section I of this Policy, which describes our collection and use of information also serves as our Notice At Collection for California residents for purposes of the California Consumer Privacy Act (CCPA). If you are a California resident and would like to exercise one of your California Privacy Rights, you may do so by submitting a request by filling out this form with your name, address, email address, and phone number or calling us at 1-855-449-0010 for Cox Automotive, Inc.’s Applicants or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Applicants. Please carefully review Section VII (California Privacy Rights) before doing so.

ABOUT THIS APPLICANT PRIVACY POLICY

The purpose of this Policy is to inform applicants about: (i) the Company’s right to access information submitted through its application systems and on its physical premises; (ii) the types of Applicant Personal Information we collect from and about you during the recruitment process, how and why we do it, who may have access to it, when we may transfer your personal information to another country, for how long we retain it, and how we protect it; (iii) our expectations of your conduct with regard to using and safeguarding Applicant Personal Information and to provide transparency; and (iv) the rights you have with respect to your Applicant Personal Information under the law that applies to you. We also monitor our information systems and facilities to create a safe and secure environment and improve the experience for our Applicants, customers and visitors.

Where we are required by law to obtain your consent to process your Applicant Personal Information, this Policy also is intended to provide sufficient information to provide your informed consent.

A Note to Applicants: Any information you submit must be true, complete, not misleading and you must have the lawful right to provide it.  If not, this may lead to a rejection of your application during the application process or, if you are employed by the Company, disciplinary action up to and including termination. If you intend to provide us with details of a reference or any other third party as part of your résumé, it is your responsibility to obtain consent from that third party prior to sharing their personal information to us. If you become an employee, any Applicant Personal Information that you submit may become part of your employment record and may be used for other employment/work-related purposes as permitted by applicable local law.

I. COLLECTION AND USE OF APPLICANT PERSONAL INFORMATION

We may collect, store, use, and disclose Applicant Personal Information for business purposes consistent with applicable laws. Where we transfer Applicant Personal Information to service providers or contractors, it is for the same business purposes or compatible with the same business purposes described below and in Section II and, where appropriate, requires that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection.

We may collect and use the categories of Applicant Personal Information about you to manage your application below.

Unless otherwise noted, the disclosures contained within this Applicant Privacy Policy cover our activities in the prior 12 months from the Effective Date as well as our current practices.

Categories of Applicant Personal Information	Business Purpose(s) for Collection and Disclosure
Personal Identifiers such as your name, home/mailing address, telephone/cellphone numbers, email address, and/or other similar identifiers.	We use this information to open and maintain your application records; communicate with you regarding your application or other career opportunities at the Company; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Personal Information such as name, signature, home/mailing address, telephone number, national identification number (i.e., Social Security Number, Driver’s License), education, employment, criminal history, and employment history.	We use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Characteristics of protected classifications such as age and date of birth, race, ancestry, ethnic origin, sex, gender, gender identity, military or veteran status, medical condition, disability.	We use this information to open and maintain your application records; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use any information relating to any disability or medical condition to address our legal obligations to you, make any adjustments required to assist you in the application process and whether you are fit to undertake tasks required by your job role. We also use this to comply with U.S. Equal Employment Opportunity Commission (“EEOC”) and California Civil Rights Agency (“CCRA”) requirements, and other equal opportunity initiatives.
Internet or other electronic network activity information such as browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, and information related to your interactions with our websites.	We use this information as needed to operate our Site and systems; and to verify your identity.
Geolocation data such as your geographic location inferred from your device IP address or otherwise provided by you.	We use this information to give you the most relevant jobs in your area.
Sensory information such as call center, security camera recordings, interview recordings (e.g., videos and photos), voice recordings, and photographs, phone calls, voice mails, and video calls (e.g., Teams and Zoom meetings and recordings) made during your employment or non-employment worker arrangement.	We use this information to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of Employees and third parties, and to protect our property from theft, vandalism, and damage.   We use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use this information for internal and external marketing events, Company events, and the security of our premises and vehicles.
Professional or employment-related information such as skills, qualifications, work experience, references, recommendations, awards, certificates, and other information included in a resume, CV, application form, or cover letter; Answers to behavioral or other screening questions in an application, assessment or interview; Information contained in any websites or documents you choose to share with us; Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; Information relating to membership in civic organizations.	We use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use this information for talent management. For example, to assess and consider other job positions that may be recommended to you based on your qualifications, and workforce planning.
Non-public education information such as school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education, including any graduate or professional degrees.	We use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use this information to assess and consider other job positions that may be recommended to you based on your qualifications.
Sensitive Personal Information such as national identification number (i.e., Social Security Number, Driver’s License), citizenship or immigration status, race or ethnic origin, and information relating to any disability or medical condition that is relevant to your role, including the results of any pre-employment physical or screening examination.	We use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We use race and ethnic origin information only to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We do not use any Sensitive Personal Information for any purpose outside of the purpose for which it was shared with us.
Inferences such as characteristics, behaviors, intelligence, abilities, and aptitude.	We use this information to confirm eligibility, qualifications, and background checks. We also use this information to assess and consider other job positions that may be recommended to you based on your qualifications. To the extent permitted by applicable law, we also use this information to identify certain correlations between job applicants and job success as well as for workforce planning.

II. ADDITIONAL BUSINESS PURPOSES FOR USE AND DISCLOSURE APPLICANT PERSONAL INFORMATION

In addition to the business purposes stated in Section I above, we may also collect, use and disclose the categories of Applicant Personal Information identified above for the following business purposes:

• Facilitate employment-related processes, including workforce planning, talent management, and other activities to support and manage our workforce effectively.
• Comply with legal and regulatory obligations, including investigations, and establish or defend legal claims.
• To establish or defend legal claims and allegations.
• Ensure security and integrity, prevent, detect, or investigate fraud, illegal activity, compliance with our internal policies or rules, or other misconduct.
• Seek advice from legal, audit, and other professional advisers.
• Perform services on our behalf, such as account maintenance, customer service, transaction processing, analytics, and storage.
• Conduct internal research, verify or maintain the quality and safety of our services or devices, and improve or enhance them, such as debugging or repair errors.
• Disclose information in connection with a sale, assignment, merger, reorganization, or other transfer of our business.

III. CATEGORIES OF RECIPIENTS TO WHOM WE DISCLOSE APPLICANT PERSONAL INFORMATION FOR BUSINESS PURPOSES

• Service Providers and Contractors. To carry out the purposes described in Sections I and II above, we may disclose your Applicant Personal Information to the following types of service providers and contractors: data analytics providers, security providers, background check vendors, human resources, recruiting, employment and information technology vendors, affiliates, auditors, consultants, contractors, strategic partners, and outside legal counsel.
• Affiliates and Subsidiaries. We may disclose all categories of Applicant Personal Information to our affiliates to the extent permissible under applicable law;
• Government and Enforcement Agencies. We may disclose all categories of Applicant Personal Information to law enforcement agencies, and state or federal government agencies, for mandatory reporting, investigations or as otherwise required by law.
• Third Parties. We may disclose all categories of Applicant Personal Information to a third party in the event of any proposed reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• Other External Parties. We may disclose all categories of Applicant Personal Information when required by law or to protect the Company, Applicants or other persons, as described in this Policy.

IV. CATEGORIES OF SOURCES FROM WHICH WE COLLECT APPLICANT PERSONAL INFORMATION

We may collect Applicant Personal Information (both online and in-person), including from you, through a recruiter, from a variety of sources to facilitate your job application, operate the Site, comply with applicable laws, and other permitted purposes.

• Directly From You. For example, we collect your name, home or mailing address, telephone/cellphone numbers, email address, and other employment-related information when you apply for a job through our Site or when we interact with you or you otherwise opt-in to allow us to collect your information.
• Automatically When Using Our Electronic Systems. For example, our Site automatically collects your internet and network activity information when you apply for a job through cookies and similar technologies.
• Service Providers and Contractors. For example, background check vendors and credit agencies and bureaus, recruitment and staffing agencies.
• Affiliates and Subsidiaries. For example, we may receive certain information when you interact with our shared corporate services.
• Third-Party Sources. For example, we may receive certain information about your from publicly available sources, financial institutions, government sources, or social media and other third-party platforms where you interact with us.

V. SHARE OR SELL OF APPLICANT PERSONAL INFORMATION

We may disclose Personal Information to third parties or process your Personal Information for various purposes, including targeted advertising. These kinds of disclosures may be deemed “selling” or “sharing” under certain state privacy laws. You have the right to opt-out of the sale or processing of your Personal Information for targeted advertising as described below.

We may “sell” or “share” for cross-context behavioral advertising purposes (and may have sold or shared the following categories of Applicant Personal Information during the 12-month period prior to the Effective Date of this Applicant Privacy Policy): identifiers, internet or other electronic network activity information, and geolocation data. We will only share or sell this information through our use of cookies and other tracking technologies (such as web beacons) to our analytics and advertising partners for advertising purposes. To understand more about our use of cookies and tracking technologies on our Sites, please carefully review Section VI Cookies and Tracking Technologies.

We also do not “sell” or “share” the Personal Information of consumers under 16 years of age. Generally, an individual applying for a job at the Company must be at least 16 years old.

We may disclose aggregated or deidentified information without restriction.

VI. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our Site, including information about your browsing behavior.

Cookies are small files that a website transfers to your device through a web browser that enable the Site’s systems to recognize your device and to capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our Site uses cookies and other tracking technologies as follows:

1. Where necessary to run our Site;
2. To optimize the functionality of our Site, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or region);
3. For analytics purposes—for example, to help us understand how our Site is used.

Our Site uses analytics technology, including Google Analytics, to understand how users interact with the Site, and improve your web experience. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

VII. CALIFORNIA PRIVACY RIGHTS (CALIFORNIA APPLICANTS ONLY)

If you are a resident of California, you have the right to submit certain requests relating to your Applicant Personal Information as described below.

To exercise the right to know, right to delete, or right to correct, you may submit a request by filling out this form or calling us at 1-855-449-0010 (CAI Applicants) or 1-877-290-myHR (6947) (CCI and CEI Applicants). Do not send other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Right to Opt-Out of Share and Sale of Applicant Personal Information.

You have the right to opt out of the sale of your Applicant Personal Information (specifically: identifiers, internet or other electronic network activity information, and geolocation data) and to request that we do not share your Applicant Personal Information (specifically: identifiers, internet or other electronic network activity information, and geolocation data) for cross-context behavioral advertising.

We honor the Global Privacy Control, a browser-based opt-out preference signal turned on via your device browser, in accordance and to the extent required by applicable law. We do not respond to other browser-based signals that do not meet applicable state law requirements, which may include older Do Not Track signals.

To the extent that we “sell” or “share” your Personal Information, you have the right to opt out by:

1. enabling your opt out preference signal or Global Privacy Control on your browser
2. opting out of cookies in cookie preference center, or  
3. submitting a request to us, by clicking here.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; and for short-term, transient use, including for non-personalized advertising. For this reason, we do not treat the Sensitive Personal Information we collect as subject to a “Limit the Use of My Sensitive Personal Information” request and, therefore, we do not offer a way for you to submit such a request.

Right to Know, Delete, and Correct Applicant Personal Information.

Any Request to Know, Request to Delete, and Request to Correct you submit to us is subject to an identification and residency verification process (“Verifiable Applicant Request”). We will not fulfill your Verifiable Applicant Request unless you have provided sufficient information for us to reasonably verify you are the Applicant about whom we collected Applicant Personal Information.

If you are unable to provide us with certain information about yourself, we will be unable to verify your identity to fulfill a request to know, delete, or correct. For your request for specific pieces of information, as required by the CCPA, we may apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above. Under the CCPA there are exceptions to your request rights. If we do not comply fully with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Applicant Personal Information that we collect, process, store, disclose, and otherwise use and to respond to your requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

You may use an authorized agent to submit your request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

Right to Know. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following:

(1) The categories of Personal Information we have collected about you, including:  

(2) The specific pieces of Applicant Personal Information we have collected about you. 

Right to Delete. You may request that we delete your Applicant Personal Information that we have collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your Applicant Personal Information as permitted by applicable law, such as for legal retention requirements, regulatory reasons, to complete a contract with you, or other internal uses of the information that are compatible with the context in which you provided it. For example, we may not be able to delete your resume from our files because you may still be in the application process.

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

Right to Non-Discrimination and No-Retaliation for the Exercise of Your Privacy Rights.

If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate or retaliate against you.

VIII. COMMUNICATIONS

You can opt-out of receiving certain communications from the Company at any time either by following the instructions provided in emails to click on the unsubscribe link, by changing your communication preferences, or by exercising your right to opt-out when it is offered to you.

Please note that if you enrolled in the Site using more than one email address or telephone number, you will need to submit a separate unsubscribe request for each. Even if you unsubscribe from receiving certain types of communications, Company may, subject to applicable law, continue to send you non-promotional communications, such as those about the position for which you applied or may be interested in applying, similar job opportunities at Company, or communications relevant to your use of the Site. If you would like to completely deactivate your account, please opt-out of receiving any future communications from Company by changing your marketing communication preferences in your Site account or by contacting us at privacy@coxinc.com.

IX. CANADIAN JOB APPLICANTS ONLY

Applicants may have rights under the data protection laws where they reside. These rights may include, subject to certain exceptions, the right to access and correct Applicant Personal Information, as well as the right to withdraw consent where consent is the legal basis for processing. Applicants can learn more about and exercise these rights by submitting an email to privacy@coxinc.com. The Company will respond to such requests in compliance with applicable data protection law.

Applicants who reside in Canada give their consent to the processing of their Applicant Personal Information, including the cross-border transfer of their personal information, as described in this Policy, by affirmatively acknowledging acceptance of this Policy during the application process.

Where required by law, Applicants may withdraw their consent at any time by using the email address provided above. Any withdrawal will apply only prospectively, and the Company will continue to retain the personal information collected before the withdrawal for as long as allowed or required by applicable law. Please understand that if you do not consent to the processing of your personal information, or withdraw your consent where consent is required, the Company may not be able to process your application or consider you for employment. For example, if you do not provide the Company with information necessary to evaluate your qualifications, or if you withdraw your permission for the Company to process the information needed for recruitment, we may not be able to proceed with your application.

X. RETENTION PERIOD CRITERIA FOR APPLICANT PERSONAL INFORMATION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Applicant Personal Information (which includes the categories of Personal Information set forth in the chart above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes, after which we will securely delete, destroy, or anonymize it in accordance with applicable law and Company policies.

To determine the appropriate retention period for Applicant Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Applicant Personal Information, the potential risk of harm from unauthorized use or disclosure of your Applicant Personal Information, the purposes we process your Applicant Personal Information for, and whether we can achieve those purposes through other means.

Note that Company may delete Applicant Personal Information about you at any time (including your résumé). Therefore, please retain your own copy of any Applicant Personal Information that is provided to us during the application process.

XI. HOW WE PROTECT APPLICANT PERSONAL INFORMATION

The Company is committed to protecting Applicant Personal Information from unauthorized disclosure, use, acquisition, or loss. We employ reasonable and appropriate technical, physical, and administrative controls to safeguard our information systems that contain Applicant Personal Information. We also impose controls and contractual obligations on third parties that have access to Applicant Information.

XII. HOW WE TRANSFER APPLICANT PERSONAL INFORMATION

As a multinational corporate group, Applicant Personal Information may be transferred to, and accessed by, affiliated Companies or third parties providing services to Company located in countries other than your country of residence, including the United States and/or other jurisdictions. Company affiliates may use transferred Applicant Personal Information only for the purposes stated in this Policy and for reasonably compatible purposes. These Company affiliates will be permitted to store, or remotely access, transferred Applicant Personal Information only if they take steps to provide an adequate level of protection for that information.

XIII. CHANGES

We reserve the right to amend this Applicant Privacy Policy at any time in order to address future developments of Company, the Site or changes in industry or legal trends. We will post the revised Applicant Privacy Policy on the Site or otherwise post it where it applies. Any changes will become effective upon the posting of the revised Applicant Privacy Policy on the Site. By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Applicant Privacy Policy, in whole or part, you can choose to not continue to use the Site.

XIV. CONTACT US

If you have any questions about this Applicant Privacy Policy, please contact us at privacy@coxinc.com.

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Workforce Member Privacy Policy

Effective Date:  January 1, 2026

This Workforce Member Privacy Policy (“Workforce Member Policy”) informs former employees, beneficiaries, dependents, and next of kins (“Employee”), and current and former temporary workers, current and former contingent workers, and current and former independent contractors located in the United States and Canada (collectively, “Worker”) (Employees and Workers, altogether, “Workforce Member”) of Cox Enterprises, Inc. , Cox Automotive, Inc., Cox Communications, Inc., and their affiliates and subsidiaries (collectively the “Company” or “we” or “us” or “our”), of our practices regarding the collection, use, sale, sharing, and retention of your personal information (“Information Practices”) through the Company Employee Portals (the “Site”), our systems and facilities, and other online and in-person methods of collection, to facilitate your employment or post-employment with us as an Employee, including handling of any benefits that may be available to you, to facilitate your current or post-employment, or current or post non-employment worker arrangement with the Company as a Worker (collectively, “Workforce Member Personal Information”), or otherwise where this Policy is posted.

This Policy applies to information collected from and about individuals in their capacity as or related to their current or former employment, or as retirees, dependents, beneficiaries and current or former Independent Contractors. This Workforce Member Policy should be read in association with all other Company policies that govern your current or previous employment or non-employment worker arrangement with the Company, including, but not limited to our Applicant Privacy Policy, our Workforce Member Privacy Policy (Internal) (a copy can be provided upon request), and any additional policies provided to you as part of the off-boarding process.

For purposes of this Workforce Member Policy, Independent Contractor is defined as a natural person who provides any service to a business pursuant to a written contract. Nothing in this Workforce Member Policy shall be interpreted to serve as basis for addressing a Workforce Member’s “employment status” with the Company under any federal or state employment laws.

Please note that Section III of this Policy, which describes our collection and use of information also serves as our Notice At Collection for California residents for purposes of the California Consumer Privacy Act (CCPA). If you are a California resident and would like to exercise one of your California Privacy Rights, you may do so by submitting a request by filling out this form or calling us at 1-855-449-0010 for Cox Automotive, Inc.’s Workforce Members or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Workforce Members.

Please carefully review Section X (California Privacy Rights) of this Workforce Member Policy before doing so.

ABOUT THIS WORKFORCE MEMBER POLICY

The purpose of this Policy is to inform Workforce Members about: (i) the Company’s right to access information stored on its information systems and on its physical premises; (ii) the types of Workforce Member Personal Information we collect from and about you, how and why we do it, who may have access to it, when we may transfer your Workforce Member Personal Information to another country, for how long we retain it, and how we protect it; and (iii) the rights you have with respect to your Workforce Member Personal Information under the law that applies to you. We also monitor our information systems and facilities to create a safe and secure environment and improve the experience for our employees, customers and guests.

Where we are required by law to obtain your consent to process your Workforce Member Personal Information, this Policy also is intended to provide sufficient information to provide your informed consent.

I. COMPANY’S RIGHT TO ACCESS WORKFORCE MEMBER PERSONAL INFORMATION IN THE WORKPLACE

The Company has the right to access all information stored on, or transmitted through, its information systems and other Company-owned computer equipment. Consequently, employees should not have an expectation of privacy when accessing, connecting to, or using the Company’s information systems or devices. Employees also should not expect privacy when they are connected to the Company’s networks, regardless of whether they are using their own device, when or where they are using it, or whether it is protected by passwords, encryption, access codes, or other security measures, with respect to any information transmitted through the Company’s information systems

The Company has the right to access any information stored in file cabinets, desks, offices and similar storage locations on the Company’s premises. Consequently, employees should not have an expectation of privacy in the physical workplace other than in traditionally private spaces, such as restrooms, mother’s rooms, wellness rooms, and locker rooms.

II. CANADIAN WORKFORCE MEMBERS ONLY

Employees who reside in Canada give their consent to the processing of their employee information, including the cross-border transfer of their Workforce Member Personal Information, as described in this Policy, by affirmatively acknowledging acceptance of this Workforce Member Policy.

Employees may withdraw their consent at any time by emailing privacy@coxinc.com. Any withdrawal will apply only prospectively, and the Company will continue to retain the Workforce Member Personal Information collected before the withdrawal for as long as allowed or required by applicable law. Please understand that if you do not consent to the processing of your Workforce Member Personal Information, or withdraw your consent, where consent is required, the Company may not be able to provide you with compensation or certain benefits. For example, if you do not provide the Company with information necessary for you to participate in a benefits plan, or if you withdraw your permission for the Company to process the information needed to administer a benefits plan, you may not be able to participate in that plan.

III. COLLECTION AND USE OF WORKFORCE MEMBER PERSONAL INFORMATION

During either your employment or non-employment worker arrangement with us, we may have collected, stored, used, and disclosed your Workforce Member Personal Information for business purposes consistent with applicable laws. Where we have transferred your Workforce Member Personal Information to service providers or contractors, it is for the same business purposes or compatible with the same business purposes described below and in Section IV and, where appropriate, it is required that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection.

Depending on your Workforce Member role, as noted below, we may continue to collect, store, use, and disclose the categories of Workforce Member Personal Information about you to facilitate your post-employment or post non-employment worker arrangement with us.

Unless otherwise noted, the disclosures contained within this Workforce Member Policy cover our activities in the prior 12 months from the Effective Date as well as our current practices.

Internal policies listed below can be made available upon request to privacy@coxinc.com.

Categories of Workforce Member Personal Information	Business Purpose(s) for Collection, Use, and Disclosure
Personal Identifiers such as your name, home address, telephone/cellphone numbers, email address, and/or other similar identifiers.	We use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post-employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Personal Information such as name, signature, home/mailing address, telephone number, national identification number (i.e., Social Security Number, Driver’s License, Commercial Driver’s License), birth certificate, marriage certificate, vehicle information (e.g., car’s year/make/model and license plate), criminal history, financial information (e.g., bank account details), education, employment, employment history, medical information, and health insurance information.	We use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post-employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We use any information relating to any disability or health condition to address our legal obligations, including to assess your current or post-employment eligibility for and/or pay you any statutory or other benefits to which you may be entitled. We use your financial information to pay you or provide other current or post-employment benefits and process any current or post-employment expense claims.
Biometric Information such as facial recognition, fingerprint or hand-geometry data collected by our internal devices, facilities, and any of your devices covered by our Mobile Device Acceptable Use Policy. For more information on our Information Practices related to your biometric information, current Workforce Members can review our Biometric Information Retention and Destruction Policy posted on our Company Portal.	We use this information to provide access to our systems and facilities, such as laptops, tablets, and cellular phones, including web and mobile applications. After the off-boarding process or when you are officially a Former Workforce Member of the Company, we will stop using this information and delete it from our systems and facilities, such as laptops, tablets, and cellular phones, including web and mobile applications consistent with our Biometric Information Retention and Destruction Policy.
Internet or other electronic network activity information such as all activities on the Company’s network, devices, website, apps, and information systems, such as internet browsing history, search history, and email communications; and all activity on the Company’s communications systems during your employment or non-employment worker arrangement (including devices and apps covered by our Mobile Device Acceptable Use Policy).	We use this information to manage our corporate information technology, monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of Employees and third parties, and to protect our property from theft, vandalism, and damage.
Geolocation data such as GPS location data from company-issued mobile devices and Company-owned vehicles, or otherwise provided by you during your employment or non-employment worker arrangement.	We use this information to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of Employees and third parties, and to protect our property from theft, vandalism, and damage. We use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use this information for internal and external marketing events, Company events, and the security of our premises and vehicles.
Professional or employment-related information such employee ID number as position applied for, job roles/titles, job code, supervisory identification, hire date, work location, company/department/business unit, hourly v. salary, part-time v. full-time, work schedule, dependent and beneficiary information, performance information, pre and post-employment job history, education, awards, qualifications, certificates, licenses, financial relationships, compensation and salary information, eligibility for and participation in benefit and award programs, tax and withholding records, payroll records and any other information you choose to provide in your resumes and/or applications as well as work anniversary information and skills and experience over the employment period.	We use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post-employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use this information for talent management and workforce planning.
Sensitive Personal Information such as national identification number (i.e., Social Security Number, Driver’s License, Commercial Driver’s License), citizenship or immigration status, race or ethnic origin, religious or philosophical beliefs, or union membership, sexual orientation, biometric information, precise geolocation, and information relating to any disability or health condition that is relevant to your role, including the results of any pre- or post- employment physical or screening examination, pre and post-employment health screening, medical questionnaires and drug test information, vaccination status, workplace injury and health information associated with medical leave or disability claims.	We use this information to maintain your current or former Employee personnel records or Worker records; communicate with you for current or post-employment, or current or post non-employment worker arrangement business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We use race and ethnic origin information only to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We use any information relating to any disability or health condition to address our legal obligations to you, including to assess your current or post-employment eligibility for and/or pay you any statutory or other benefits to which you may be entitled. We do not use any Sensitive Personal Information for any purpose outside of the purpose for which it was shared with us.
Inferences such as characteristics, behaviors, intelligence, abilities, and aptitude.	We use this information to confirm eligibility, qualifications, and perform background checks. We also use this information to assess and consider other job positions that may be recommended to you based on your qualifications. To the extent permitted by applicable law, we also use this information to identify certain correlations between job applicants and job success as well as for workforce planning.
Characteristics of protected classifications such as age and date of birth, marital status, race, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, disability. Employees only.	We use this information to maintain your current or former Employee personnel records; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Non-public education information such as school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education, including any graduate or professional degrees. Employees only.	We use this information to maintain your current or former Employee personnel records; communicate with you for current or post-employment business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Other Categories of Workforce Member Personal Information National identification information such as your country of birth or the country where you are a registered national or citizen, and any visa or other right to work. Benefits information such as national insurance numbers, and information about your pension and other welfare or benefits. This may also include information about any beneficiaries, dependents, emergency contacts and next of kin. Employees, beneficiaries, and dependents only.	We use this information to maintain your current or former Employee personnel records; communicate with you for current or post-employment business purposes or emergencies; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We also use this information to assess your current or post-employment eligibility for and/or pay you any statutory or other benefits to which you may be entitled. We also use this information to contact the designated contacts in the case of an emergency.

IV. ADDITIONAL BUSINESS PURPOSES FOR USE AND DISCLOSURE OF WORKFORCE MEMBER PERSONAL INFORMATION

In addition to the business purposes stated in Section III above, we may also collect, use and disclose the categories of Workforce Member Personal Information identified above for the following business purposes:

• Facilitate employment-related processes, including workforce planning, talent management, and other activities to support and manage our workforce effectively.
• Comply with legal and regulatory obligations, including investigations, and establish or defend legal claims.
• Ensure security and integrity, prevent, detect, or investigate fraud, illegal activity, compliance with our internal policies, or other misconduct.
• Seek advice from legal, audit, and other professional advisers.
• Perform services on our behalf, such as account maintenance, customer service, transaction processing, analytics, and storage.
• Conduct internal research, verify or maintain the quality and safety of our services or devices, and improve or enhance them, such as debugging or repair errors.
• Enable short-term, transient uses (e.g., non-personalized advertising during your current interaction) without building profiles or altering your experience outside that interaction.
• Disclose information in connection with a sale, assignment, merger, reorganization, or other transfer of our business.

V. CATEGORIES OF RECIPIENTS TO WHOM WE DISCLOSE WORKFORCE MEMBER PERSONAL INFORMATION FOR BUSINESS PURPOSES

• Service Providers and Contractors. To carry out the purposes described in Sections III and IV above, we may disclose your Workforce Member Personal Information to the following types of service providers and contractors: data analytics providers, security providers, background check vendors, credit reporting agencies, human resources, employment and information technology vendors, affiliates, auditors, consultants, contractors, retirement plan administrators, strategic partners, and outside legal counsel.
• Affiliates and Subsidiaries. We may disclose all categories of Workforce Member Personal Information to our affiliates to the extent permissible under applicable law;
• Government and Enforcement Agencies. We may disclose all categories of Workforce Member Personal Information to law enforcement agencies, and state or federal government agencies, for mandatory reporting or as otherwise required by law.
• Third Parties. We may disclose all categories of Workforce Member Personal Information to a third party in the event of any proposed reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• Other External Parties. We may disclose all categories of Workforce Member Personal Information when required by law or to protect the Company, Workforce Members or other persons, as described in this Policy.

VI. CATEGORIES OF SOURCES FROM WHICH WE COLLECT WORKFORCE MEMBER PERSONAL INFORMATION

We may collect Workforce Member Personal Information (both online and in-person) from our Talent Community and Applicant Tracking System (the “Applicant Site”) when you were a job applicant, from the Company Employee Portal (the “Employee Site”) (collectively, “CEI Employment Sites”), and from a variety of sources to facilitate your current or former employment, or current or former non-employment worker arrangement with us, to comply with applicable laws, and other permitted business purposes.

• Directly From You. For example, we collected your name, home or mailing address, telephone/cellphone numbers, email address, and other employment-related information when you applied for a job as an applicant and when you were onboarded as an Employee or when we interact with you or you otherwise opt-in to allow us to collect your information.
• Automatically When Using Our Electronic Systems. For example, our internal electronic systems automatically collected your internet and network activity information through cookies and similar technologies.
• Service Providers and Contractors. For example, background check vendors, recruitment and staffing agencies, credit agencies and bureaus, and benefit providers.
• Affiliates and Subsidiaries. For example, we may receive certain information from you when you interact with our shared corporate services.
• Third-Party Sources. For example, we may receive certain information about your from publicly available sources (such as social media), financial institutions or government sources.

VII. SHARE OR SELL OF WORKFORCE MEMBER PERSONAL INFORMATION

We do not “share” or “sell” your Workforce Member Personal Information to third parties, as those terms are defined in the CCPA. However, we may disclose aggregated or deidentified information without restriction.

We also do not “sell or “share” the personal information of consumers under 16 years of age. Generally, to be a Workforce Member at the Company, an individual must be at least 16 years old.

VIII. COMMUNICATIONS

You can opt-out of receiving certain communications from the Company at any time either by following the instructions provided in emails to click on the unsubscribe link, by changing your communication preferences, or by exercising your right to opt-out when it is offered to you.

Please note that your opt-out is limited to the address, e-mail, or phone number used and will not affect other communications. however, if you opt-out of receiving certain communications, the Company may, subject to applicable law, continue to send you certain other communications, such as any communications relevant to your employment with the Company.

IX. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our Site, including information about your browsing behavior.

Cookies are small files that a website transfers to your device through a web browser that enable the Site’s systems to recognize your device and to capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our Site uses cookies and other tracking technologies as follows:

1. Where necessary to run our Site;
2. To optimize the functionality of our Site, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or region);
3. For analytics purposes—for example, to help us understand how our Site is used.

Our Site uses analytics technology, including Google Analytics, to understand how users interact with the Site, and improve our web experience. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

X. CALIFORNIA PRIVACY RIGHTS (CALIFORNIA WORKFORCE MEMBERS ONLY)

If you are a resident of California, you have the right to submit certain requests relating to your Workforce Member Personal Information as described below. To exercise the right to know, right to delete, or right to correct, you may submit a request by filling out this form or calling us at 1-855-449-0010 for Cox Automotive, Inc.’s Workforce Members or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Workforce Members. Do not send your privacy request or other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Right to Opt-Out of Share and Sale of Workforce Member Personal Information.

As stated above, we do not share or sell your Workforce Member Personal Information to third parties. For this reason, we do not treat Workforce Member Personal Information collected by us as subject to a “Do Not Share or Sell” request and, therefore, we do not offer a way for you to submit such a request.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including, as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. For this reason, we do not treat the Sensitive Personal Information we collect as subject to a “Limit the Use of My Sensitive Personal Information” request and, therefore, we do not offer a way for you to submit such a request.

Right to Know, Delete, and Correct Workforce Member Personal Information.

Any Request to Know, Request to Delete, and Request to Correct you submit to us is subject to an identification and residency verification process (“Verifiable Workforce Member Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Employee or Worker about whom we collected Workforce Member Personal Information.

If you are unable to provide us with certain information about yourself, we will be unable to verify your identity to fulfill a request to know, delete, or correct. For your request for specific pieces of information, as required by the CCPA, we may apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.

We will make commercially reasonable efforts to identify Workforce Member Personal Information that we collect, process, store, disclose, and otherwise use and to respond to your requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

You may use an authorized agent to submit your request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

Right to Know. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following:

(1) The categories of Workforce Member Personal Information we have collected about you, including:

(2) The specific pieces of Workforce Member Personal Information we have collected about you.

Right to Delete. You may request that we delete your Workforce Member Personal Information that we have collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your Workforce Member Personal Information as permitted by applicable law, such as for legal retention requirements, regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it.

For example, for former Employees, we may not be able to delete your benefits information, including information about any beneficiaries, dependents, emergency contacts and next of kin because we may need it to facilitate your post-employment benefits such as 401(k) or other retirement plans that may be available to you. We may also not be able to delete your health insurance information if you decide to sign up for Continuation of Health Coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA).

Right to Correct. If you believe that any of your Workforce Member Personal Information, we maintain about you is inaccurate, you have the right to request that we correct that information.

To exercise the right to know, right to delete, or right to correct, you may submit a request by filling out this form with your name, address, email address, and phone number or calling us at 1-855-449-0010 for Cox Automotive, Inc.’s Workforce Members or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Workforce Members. Do not send other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Right to Non-Discrimination and No-Retaliation for the Exercise of Your Privacy Rights.

If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate or retaliate against you.

XI. RETENTION PERIOD CRITERIA FOR WORKFORCE MEMBER PERSONAL INFORMATION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Workforce Member Personal Information (which includes the categories of Personal Information set forth in the chart above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal obligations, or as necessary to resolve disputes.

For US-based employees, beneficiaries, dependents, and retirees, Workforce Member Personal Information is maintained in accordance with our internal policies on record retention and management, and biometric retention and destruction. These internal policies govern when and how we retain certain Company information (which may include Workforce Member Personal Information) depending on the type of information, business needs, and legal and compliance requirements. These internal policies can be made available upon request to privacy@coxinc.com.

To determine the appropriate retention period for Workforce Member Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Workforce Member Personal Information, the potential risk of harm from unauthorized use or disclosure of your Workforce Member Personal Information, the purposes we process your Workforce Member Personal Information for, and whether we can achieve those purposes through other means.

As you leave the Company, and depending on your Workforce Member role, we may retain your Workforce Member Personal Information for as long as required by applicable laws.

XII. HOW WE PROTECT WORKFORCE MEMBER PERSONAL INFORMATION

The Company is committed to protecting Workforce Member Personal Information from unauthorized disclosure, use, acquisition, or loss. We employ reasonable and appropriate technical, physical, and administrative controls to safeguard our information systems that contain Workforce Member Personal Information. We also impose controls and contractual obligations on third parties that have access to Workforce Member Personal Information.

You should immediately report suspected or actual unauthorized disclosure, use, acquisition, or loss of Workforce Member Personal Information (e.g., loss of a device or file containing employee information; improper use by an individual with otherwise legitimate access to a Company information system or device; unauthorized access of an email account or tool containing employee information) to your manager, information security team (at cyberincident@coxinc.com), and to IT Help via the Report A Data Spill help ticket.

XIII. HOW WE TRANSFER WORKFORCE MEMBER PERSONAL INFORMATION

As a multinational corporate group, Workforce Member Personal Information may be transferred to, and accessed by, affiliated Companies or third parties providing services to Company located in countries other than your country of residence, including the United States and/or other jurisdictions. Only Company employees with a legitimate, business need to know will be authorized to access Workforce Member Personal Information transferred from another country. Company affiliates may use transferred Workforce Member Personal Information only for the purposes stated in this Policy and for reasonably compatible purposes. These Company affiliates will be permitted to store, or remotely access, transferred Workforce Member Personal Information only if they take steps to provide an adequate level of protection for that information.

XIV. CHANGES

We reserve the right to amend this Workforce Member Policy at any time in order to address future developments of Company or changes in industry or legal trends. We will post the revised Workforce Member Policy on our website or inform you through various methods.

XV.  CONTACT US

If you have any questions about this Workforce Member Privacy Policy, please contact us at privacy@coxinc.com.