California Privacy Notice

Effective Date: January 1, 2023

Welcome! Thank you for your interest in Cox Enterprises, Inc. and our “Affiliates” (other companies within the Cox Enterprises, Inc. corporate family, collectively “CEI” or “we” or “our” or “us”). We respect your privacy when you use our websites, which may include but is not limited to https://www.Coxenterprises.com, https://www.Coxconservesheroes.com, and https://www.Coxalert.com, and other online products and services (collectively, our “Services”). Certain Affiliates, such as Cox Automotive Inc. (“CAI”), Cox Communications, Inc. (“CCI”), and The Atlanta Journal-Constitution (“AJC”), may be subject to separate privacy notices that should be consulted when you visit their websites or other applicable properties.

This California Privacy Notice (“CA Notice”) applies to California residents that are “Consumers” as defined by the California Consumer Privacy Act (as amended and together with related regulations “CCPA”) and is a supplement to CEI’s other privacy policies or notices, including our main Privacy Policy. This CA Notice also applies to businesses with which we have a prospective or existing business relationship (“B2B Individual”), including corporate clients, business partners, service providers, suppliers, vendors, and other persons in the context of business-to-business activities (“B2B Services”).

This CA Notice reflects our practices regarding the Collection, use, Sale, Sharing, and retention of your Personal Information (“Information Practices”) as a California Consumer when you use our Services. If you are a current employee or contractor (with CEI Systems access) of CEI, you may view our California Workforce Member Privacy Notice (Internal) under “Policies and Guidelines” through InsideCox. If you are a job applicant, you may view our California Applicant Privacy Notice by visiting the CEI Careers page here. If you are a former employee, retiree, beneficiary, dependent, former contractor, or current contractor (without CEI system access) of CEI, you may view our California Workforce Member Notice (External) by visiting our main page here.

In the event of a conflict between this CA Notice and our main Privacy Policy, or our other privacy policies, this CA Notice shall govern as to our rights or obligations under the CCPA. Capitalized terms that are used herein shall have the meaning given to them in the CCPA unless otherwise noted. We may from time-to-time update information in this CA Notice regarding our Information Practices and your rights, modify our methods for responding to your requests, or supplement our responses to your requests as required to reflect updates to the law. You can tell when this CA Notice was last updated by looking at the Effective Date at the top of the CA Notice. Any changes to this CA Notice will become effective upon posting of the revised CA Notice on the Services.

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

I. Collection, Use and Disclosure of Personal Information

Generally, we Collect, use, and disclose your Personal Information (“PI”) to provide you our Services or as otherwise related to the operation of our business, including facilitating any B2B Services. In addition, we may Collect, use, and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this CA Notice. Note that the examples of PI we Collect about you, the Business Purposes, the recipients of your PI, and the sources of your PI, may vary depending on the nature of your interactions with us, and may not include all of the examples listed below. If you’re a B2B Individual, not all of the disclosures below may be applicable to facilitating B2B Services.

Information We Collect

Depending on your interaction with us, the table below provides the categories of PI and Sensitive PI we Collect about California Consumers, including B2B Individuals, and examples of the PI we Collect. We Collect, retain, use, and disclose the PI we Collect for the CCPA-defined business purposes in the bulleted list below and for the purposes described in our Privacy Policy (collectively, our “Business Purposes”). We disclose the PI we Collect to the categories of recipients below for the same Business Purposes.

Categories of PI and Sensitive PI	Business Purposes for Collection, Use, and Disclosure	Categories of Recipients to whom PI is Disclosed for a Business Purpose
Identifiers such as name, nicknames, aliases, contact information including email, phone, and address, User IDs, passwords, IP addresses, device IDs, and account names and numbers.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Facilitating the B2B Services, including providing and receiving products and services, verifying your information, processing payments, and similar functions and services; Detecting security incidents and protecting against malicious, deceptive, or illegal activity; Troubleshooting our Services to identify and repair issues; Short-term, transient use without disclosing PI to another Third Party or using to build a Consumer profile or altering an individual Consumer’s experience outside the current interaction with us; Internal research and development; Quality and safety assurance, and improving, upgrading, and enhancing our Services; Processing and managing interactions and transactions for our Services; Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, vendors that assist us in providing our Services and running our internal business operations (“Vendors”), analytics and advertising partners, and business partners.
Personal records (any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code) such as financial information.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Facilitating the B2B Services, including providing and receiving products and services, verifying your information, conducting background checks and pre-screening examination, processing payments, and similar functions and services; Troubleshooting our Services to identify and repair issues; Processing and managing interactions and transaction for Services.	Affiliates, Vendors, and business partners.
Characteristics of protected classifications under California or federal law such as age, gender, and household information.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Internal research and development; Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.
Commercial information such as purchase or service history.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Facilitating the B2B Services, including providing and receiving products and services, verifying your information, processing payments, and similar functions and services; Detecting security incidents and protecting against malicious, deceptive, or illegal activity; Troubleshooting our Services to identify and repair issues; Internal research and development; Quality and safety assurance, and improving, upgrading, and enhancing our Services; Processing and managing interactions and transactions for our Services; Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, and business partners.
Internet or other electronic network activity information such as browsing history, referring URLs, search history, interactions with advertising links, and mobile application usage.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Facilitating the B2B Services, including providing and receiving products and services, verifying your information, processing payments, and similar functions and services Detecting security incidents and protecting against malicious, deceptive, or illegal activity; Troubleshooting our Services to identify and repair issues; Short-term, transient use without disclosing PI to another Third Party or using to build a Consumer profile or altering an individual Consumer’s experience outside the current interaction with us; Internal research and development; Quality and safety assurance, and improving, upgrading, and enhancing our Services; Processing and managing interactions and transactions for our Services; Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.
Geolocation data such as your location we infer based on your IP address.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Short-term, transient use without disclosing PI to another Third Party or using to build a Consumer profile or altering an individual Consumer’s experience outside the current interaction with us; Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.
Sensory data (audio, electronic, visual) such as voice recordings from call centers or profile photos you place on your profile.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Facilitating the B2B Services, including providing and receiving products and services, verifying your information, facility access, processing payments, and similar functions and services; Quality and safety assurance, and improving, upgrading, and enhancing our Services; Processing and managing interactions and transactions for our Services.	Affiliates, Vendors, and business partners.
Inferences from PI Collected such as customer profiles including subscriber preferences, customer characteristics, and behaviors.	Providing our Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, auditing compliance, and similar functions and services; Internal research and development; Quality and safety assurance, and improving, upgrading, and enhancing our Services; Processing and managing interactions and transactions for our Services; Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.

In addition, each of the above referenced categories of PI may be Collected, used, and disclosed with the government, including law enforcement, or other parties to comply with law or legal process, to the Consumer or other parties at the Consumer’s request, for the additional purposes explained in our Privacy Policy, for other operational or business purposes reasonably necessary and proportionate to achieve the purposes for which the PI is Collected, and to assignees as part of a merger or asset sale. Further, we may Deidentify or Aggregate your PI, and as permitted by applicable law, we do not treat Deidentified or Aggregate Consumer information as PI. Similarly, as permitted by the CCPA, we may not treat publicly available information as PI.

Sources of PI
We Collect the above categories of PI directly from you, your device or browser, Vendors, suppliers, public databases, social media platforms, data append services, Affiliates, and for B2B Individuals, the Business that we have a prospective or existing business relationship with.

II. Retention of PI

Except as otherwise permitted or required by applicable law or regulation, we will only retain your PI (which includes the categories of PI set forth in the charts 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. To determine the appropriate retention period for PI, we consider applicable legal requirements, the amount, nature, and sensitivity of the PI, the potential risk of harm from unauthorized use or disclosure of your PI, the purposes we Process your PI for, and whether we can achieve those purposes through other means. For certain types of PI, we will only maintain it for a limited duration.

IV. California Privacy Rights

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

Right to Opt-Out of Share and Sale of Your Personal Information
1. Exercising Opt-Out Rights
  You have the right to direct us to not Sell or Share your PI, as defined under the CCPA. Our use of cookies for advertising and marketing are considered a “Sale” or “Sharing” under the CCPA. We provide Californians who use our Services a way to manage their cookie preferences based on categories of cookies through our management tool available here, or by clicking on the “Do Not Sell or Share My Personal Information” button in the footer of our website. You will need to do this on each browser and each device that you use to access our Services and clearing cookies on your browser(s) may disable your preference settings. More information on how to exercise choices regarding Third Party cookies and interest-based advertising is available here.
2. Opt-Out Preference Signals
  You may also opt out of the Sale or Sharing of your PI 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 opt-out preference signal, you will need to turn it on for each browser and each device you use.
3. California Minors
  We do not knowingly Share or Sell the PI of Consumers we know are under 16. Any California residents under the age of 18 who have registered to use our Services, and who posted content or information on our websites, can request removal by contacting us at privacy@coxinc.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, other parties may have republished or archived content by search engines and others that we do not control.
Right to Limit Use and Disclosure of Your Sensitive Personal InformationWe do not use or disclose Sensitive PI for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to provide our goods and services, or 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 PI we process as subject to a limit use and disclosure request and, therefore, we do not offer a way for you to submit such a request.
Right to Know, Delete, and Correct Your Personal InformationCalifornia Consumers have the right to exercise certain privacy rights under the CCPA. 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 Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI.
If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know , delete, or correct. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.

Some personal information we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. Under the CCPA they 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 Consumer PI that we Collect, Process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights 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 a Consumer rights 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.
1. The 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 PI we have Collected about you, including:
    1. The categories of sources from which the PI was Collected
    2. Our Business or Commercial Purposes for Collecting, Selling, or Sharing PI
    3. The categories of Third Parties to which we disclose PI
    4. The categories of PI that we Sold or Shared, and for each category identified, the categories of Third Parties to which we Sold or Shared that particular category of PI
    5. The categories of PI that we disclosed for a Business Purpose, and for each category identified, the categories of Third Parties to which we disclosed that particular category of PI
  2. The specific pieces of PI we have Collected about you.
2. The Right to Deletion
  You may request that we delete your PI that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your PI as permitted by applicable law, such as for 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. Note also that we are not required to delete your PI that we did not Collect directly from you.
3. The Right to Correct
  If you believe that any of your PI we maintain about you is inaccurate, you have the right to request that we correct that information. Note that we may deny your request if we determine that the contested PI is more likely than not accurate based on the totality of the circumstances, including the nature of the PI, how we obtained the contested PI, and documentation relating to the accuracy of the PI. We may also delete the contested PI as an alternative to correcting the information only if the deletion of PI does not negatively impact you, or you give us consent to delete the contested PI.
  To exercise the right to know, right to delete, or right to correct, you may submit a request by clicking here or calling us at 1-800-933-9771 and including your name, address, email address, and phone number. 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 for the Exercise of Your Privacy Rights
CEI will not discriminate against any Consumer for exercising their rights under the CCPA.

V. California Shine the Light Law

Separate from your CCPA rights, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at privacy@coxinc.com or by sending a letter to:

Cox Enterprises Inc.
ATTN: Chief Privacy Officer: Shine the Light Request
6205-A Peachtree Dunwoody Road
Atlanta, GA 30328

Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

VI. Contact Us

If you have any questions about this CA Notice, please contact CEI at privacy@coxinc.com. Requests under Section 4 California Privacy Rights will not be accepted via email.

California Applicant Privacy Notice

Effective Date: January 1, 2024

This California Applicant Privacy Notice (“Applicant Notice”) informs individuals applying for or interested in applying for a role at Cox Enterprises, Inc. or one of its affiliates, (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 through our Talent Community and Applicant Tracking System (the “Site”), including through a recruiter, to facilitate your job application (“Applicant Personal Information”). This Applicant Notice should be read in association with all other Company policies that may be provided to you as part of the application process.

If you 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 VIII California Privacy Rights before doing so.

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.

Categories of Applicant Personal Information	Business Purpose(s) for Collection and Disclosure
Personal Identifiers such as your name, home address, telephone/cellphone numbers, email address, and/or other similar identifiers.	We will 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.
Personal Information Described in Subdivision I of Section 1798.80 such as name, signature, address, telephone number, national identification number (i.e., Social Security Number, Driver’s License), education, employment, and employment history.	We will 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 may 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 may 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 will 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 will use this information as needed to operate our Site and systems.
Geolocation data such as your geographic location inferred from your device IP address or otherwise provided by you.	We will use this information to give you the most relevant jobs in your area.
Sensory information such as security camera recordings and photographs.	We will 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.
Professional or employment-related information such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; Answers to behavioral or other screening questions in an application 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 will 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 will also use this information to assess and consider other job positions that may be recommended to you based on your qualifications.
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 will 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 will also use this information to assess and consider other job positions that may be recommended to you based on your qualifications.
Inferences such as applicant’s characteristics, behaviors, intelligence, abilities, and aptitude.	We may use this information to confirm eligibility, qualifications, and background checks. We may 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 will 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.

In addition to the business purposes set forth above, we may collect, use, and disclose the categories of Applicant Personal Information identified above:

To comply with applicable legal and regulatory requests and obligations (including investigations).
To establish or defend legal claims and allegations.
For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
To seek advice from lawyers, auditors, and other professional advisers.
To disclose to another party in connection with the sale, assignment, merger, reorganization, or other transfer.

II. Additional Business Purposes for Use and Disclosure Applicant Personal Information

We may also use and disclose the categories of Applicant Personal Information identified above for the following business purposes:

Helping to ensure security and integrity to the extent the use of your Applicant Personal Information is reasonably necessary and proportionate for these purposes;
Debugging to identify and repair errors that impair existing intended functionality;
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, providing storage, or providing similar services on our behalf;
Undertaking internal research for technological development and demonstration; and
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

III. 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 PI 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.

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.

For example, we will retain your Applicant Personal Information, during the entire application process to fulfill the purposes described above, including but not limited to: opening and maintaining your application records; communicate with you regarding your application; and confirm eligibility, qualification, and background checks. At the conclusion of the application process if you do not commence employment with Cox, we may retain your Applicant Personal Information for as long as required by applicable laws, including but not limited to: Title VII of the Civil Rights Act of 1964; the Age Discrimination in Employment Act of 1967; American Disabilities Act of 1990; and for California Applicants, California Government Code Section 12946.

IV. Categories of Recipients to Whom Applicant Personal Information May Be Disclosed for Business Purpose

To carry out the purposes described above, we may disclose your Applicant Personal Information to the following recipients: data analytics providers, background check vendors, human resources, recruiting, and information technology vendors, affiliates, outside legal counsel, and state or federal governmental agencies.

V. Categories of Sources From Which Applicant Personal Information May Be Collected

We may collect Applicant Personal Information on this Site, including 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 address, telephone/cellphone numbers, email address, and other employment-related information when you apply for a job through our Site.
Automatically When Using Our Electronic Systems. For example, our Site automatically collects your internet and network activity information when you apply for a job.
Service Providers and Contractors. For example, background check vendors and credit agencies and bureaus, recruitment and staffing agencies.
Affiliates. For example, we may receive certain information when you interact with our shared corporate services.

VII. 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 website use cookies and other tracking technologies as follows:

Where necessary to run our Site;
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);
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, improve our web experience, and better market our products. 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.

VIII. California Privacy Rights

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

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. To opt-out, please click here.

We will not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to provide our goods and services, or 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 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 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. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your request for specific pieces of information, as required by the California Consumer Privacy Act (“CCPA”), we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above. Under the CCPA they 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:

The categories of Applicant Personal Information we have collected about you, including:
1. The categories of sources from which the Applicant Personal Information was collected
2. Our business or commercial purposes for collecting, selling, or sharing Applicant Personal Information
3. The categories of recipients to which we disclose Applicant Personal Information
4. The categories of Applicant Personal Information that we sold or shared, and for each category identified, the categories of third parties to which we sold or shared that particular category of Applicant Personal Information
5. The categories of Applicant Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Applicant Personal Information
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 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, we may not be able to delete your resume from our files because you may still be in the application process. Note also that we are not required to delete your Applicant Personal Information that we did not collect directly from you.

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.

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 (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 Non-Discrimination for the Exercise of Your Privacy Rights.

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

IX. Communications

You can elect to unsubscribe from certain promotional communications (emails or text messaging) from Company at any time either by following the instructions provided in a Company email to click on the unsubscribe link or by changing the marketing communication preferences settings in your account. 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.

X. Change in Statement

We reserve the right to amend this Applicant Notice 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 Notice on the Site. Any changes will become effective upon the posting of the revised Applicant Notice 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 Notice, in whole or part, you can choose to not continue to use the Site.

XI. Contact Us

If you have any questions about this Applicant Notice, please contact us at privacy@coxinc.com. Requests under Section IX California Privacy Rights will not be accepted via email.

California Workforce Member Privacy Notice

Effective Date: January 1, 2024

This California Workforce Member Privacy Notice (“Workforce Member Notice”) informs current and 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 (collectively, “Worker”)(Former Employees and Former Workers, altogether, “Workforce Member”) of Cox Enterprises, Inc. or one of its affiliates, (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 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, or 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”).

For purposes of this Workforce Member Notice, 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 Notice shall be interpreted to serve as basis for addressing a Workforce Member’s “employment status” with the Company under California employment laws, including Cal. Labor Code 2750.3.

This Workforce Member Notice 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 California Applicant Privacy Notice, our California Workforce Member Privacy Notice (Internal) (a copy can be provided upon request), and any additional policies provided to you as part of the off-boarding process.

If you 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 Workforce Members or 1-877-290-myHR (6947) for Cox Communications, Inc. and Cox Enterprises, Inc.’s Workforce Members. Please carefully review Section VII (California Privacy Rights) of this Workforce Member Notice before doing so.

I. 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 II 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 Notice cover our activities in the prior 12 months from the Effective Date as well as our current practices.

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 will continue to 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 Described in Subdivision (e) of Section 1798.80 such as name, signature, address, telephone number, national identification number (i.e., Social Security Number, Driver’s License, Commercial Driver’s License), vehicle information (e.g., car’s year/make/model and license plate), financial information (e.g., bank account details), education, employment, employment history, medical information, and health insurance information.	We will continue to 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 will also continue to 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 will also continue to use your financial information to pay you or provide other current or post-employment benefits and process any current or post-employment expense claims.
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 will continue to 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.
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 will 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 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.	We will continue to 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 will continue to 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 will also continue to use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Sensory information such as security camera recordings (e.g., videos and photos), voice recordings, 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 will continue to 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 will also continue to use this information to comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We will also continue to use this information for internal and external marketing events, Company events, and premise security.
Professional or employment-related information such as position applied for, previous job roles, education, awards, qualifications, certificates, licenses, financial relationships, compensation and salary information, eligibility for and participation in benefit and award programs, 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 will continue to 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.
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 will continue to 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.
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.	We will continue to 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 will also continue to 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.
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 will continue to 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 will also continue to 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 will also continue to use this information to contact the designated contacts in the case of an emergency.

In addition to the business purposes set forth above, we may collect, use, and disclose the categories of Workforce Member Personal Information identified above:

To comply with applicable legal and regulatory requests and obligations (including investigations).
To establish or defend legal claims and allegations.
For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
To seek advice from lawyers, auditors, and other professional advisers.
To disclose to another party in connection with the sale, assignment, merger, reorganization, or other transfer.

II. Additional Business Purposes for Use and Disclosure Of Workforce Member Personal Information

We may also use and disclose the categories of Workforce Member Personal Information identified above for the following business purposes:

Helping to ensure security and integrity to the extent the use of your Workforce Member Personal Information is reasonably necessary and proportionate for these purposes;
Debugging to identify and repair errors that impair existing intended functionality;
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying Workforce Member information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
Undertaking internal research for technological development and demonstration; and
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

III. 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 PI 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.

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, including but not limited to: Title VII of the Civil Rights Act of 1964; the Age Discrimination in Employment Act of 1967; American Disabilities Act of 1990; Fair Labor Standards Act; Family Medical Leave Act; Immigration Reform and Control Act; Immigration and Nationality Act; Employee Retirement Income Security Act; Federal Insurance Contribution Act; Internal Revenue Code; Occupational Health & Safety Act; and for California Employees, California Government Code Section 12946; or as required by our non-employment worker arrangement(s) and agreement(s).

For example, under the Employee Retirement Income Security Act or ERISA, any Workforce Member Personal Information used to determine benefits that are or will become due for each Employee participating in the plan must be retained as long as they are relevant (i.e., as long as employee benefits are due and payable).

IV. Categories of Recipients to Whom Workforce Member Personal Information May Be Disclosed for Business Purpose

To carry out the purposes described above, we may disclose your Workforce Member Personal Information to the following recipients: data analytics providers, security providers, background check vendors, credit reporting agencies, human resources and information technology vendors, affiliates, outside legal counsel, and state or federal governmental agencies.

V. Categories of Sources From Which Workforce Member Personal Information May Be Collected

We may have collected Workforce Member Personal Information 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 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.
Automatically When Using Our Electronic Systems. For example, our internal electronic systems automatically collected your internet and network activity information.
Service Providers and Contractors. For example, background check vendors, recruitment and staffing agencies, credit agencies and bureaus, and benefit providers.
Affiliates. For example, we may receive certain information from you when you interact with our Center of Excellence.

VII: 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.

Where necessary to run our Site;
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);
For analytics purposes—for example, to help us understand how our Site is used.

VIII. California Privacy Rights

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.

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

As stated above, we will 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 will not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to provide our goods and services; 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.

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.

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:

The categories of Workforce Member Personal Information we have collected about you, including:
1. The categories of sources from which the Workforce Member Personal Information was collected
2. Our business or commercial purposes for collecting Workforce Member Personal Information
3. The categories of recipients to which we disclose Workforce Member Personal Information
4. The categories of Workforce Member Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Workforce Member Personal Information
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).

Note also that we are not required to delete your former Workforce Member Personal Information that we did not collect directly from you.

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 for the Exercise of Your Privacy Rights.

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

IX. Change in Statement

We reserve the right to amend this Workforce Member Notice 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 Notice on our website or inform you through various methods

X. Contact Us

If you have any questions about this Workforce Member Notice, please contact us at privacy@coxinc.com. Note that CCPA requests under Section VIII California Privacy Rights will not be accepted via email.

California Privacy Notice

California Applicant Privacy Notice

California Workforce Member Privacy Notice

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