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This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the Propeller, Inc. (Oregon) and Propeller Consulting, Inc. (California), dba Propeller (“Propeller” or “We”) Privacy Policy https://propeller.com/privacy and applies solely to visitors, users, employees, applicants, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Propeller collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information within the last 12 months:

Category	Retention Period	Examples	Collected from Website Users	Collected from Employees and Applicants
A. Identifiers.	As required by law or as long as necessary for a business purpose, whichever is longer.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	As required by law or as long as necessary for a business purpose, whichever is longer.	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES	YES
C. Protected classification characteristics under California or federal law.	As required by law or as long as necessary for a business purpose, whichever is longer.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO	YES
D. Commercial information.	N/A	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO	NO
E. Biometric information.	N/A	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	NO
F. Internet or other similar network activity.	As required by law or as long as necessary for a business purpose, whichever is longer.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES	YES
G. Geolocation data.	N/A	Physical location or movements.	NO	NO
H. Sensory data.	N/A	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	NO
I. Professional or employment- related information.	As required by law or as long as necessary for a business purpose, whichever is longer.	Current or past job history or performance evaluations.	NO	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	N/A	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO	NO
K. Inferences drawn from other personal information.	N/A	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	NO

Sensitive Personal Information

Sensitive personal information (“SPI”) is a subtype of personal information consisting of specific information categories. In particular, we have collected the below categories of SPI from employees and applicants within the last 12 months. While Propeller collects information that falls within the sensitive personal information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.

Sensitive Personal Information Category	Retention Period	Business Purpose(s)	Collected
Government identifiers, such as your Social Security number, driver's license, state identification card, and passport and visa information, and immigration status and documentation.	N/A	N/A	YES, only as needed during an employee’s hiring process.
Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password.	N/A	N/A	NO
Precise geolocation, such as physical access to a Company office location, or the location of a delivery, sales, or other employee in the field.	N/A	N/A	NO
Racial or ethnic origin.	As required by law or as long as necessary for a business purpose, whichever is longer.	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy	YES, only if provided by Applicant or Employee (optional)
Religious or philosophical beliefs.	As required by law or as long as necessary for a business purpose, whichever is longer.	Review and process religious reasonable accommodation requests Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents	YES, only if provided by Applicant or Employee in cover letter or resume
Union membership.	As required by law or as long as necessary for a business purpose, whichever is longer.	Implement appropriate policies and procedures Deduct union dues from paychecks	YES, only if provided by Applicant or Employee in cover letter or resume
Mail, email, or text messages contents not directed to the Company.	As required by law or as long as necessary for a business purpose, whichever is longer.	Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents	YES, only as needed regarding employees for the purposes stated.
Genetic data.	As required by law or as long as necessary for a business purpose, whichever is longer.	Investigate and process workers' compensation claims Process health insurance claims Conduct and process employment testing	YES, only as needed regarding employees for the purposes stated.
Unique identifying biometric information.	N/A	N/A	NO
Health information, including job restrictions and workplace illness and injury information.	As required by law or as long as necessary for a business purpose, whichever is longer.	Investigate and process workers' compensation claims Process health insurance claims Conduct and process employment testing Ensure equal access to retirement programs and fertility planning by same‑sex spouses Ensure equal family leave policies and insurance for transgender surgeries	YES, only if provided by Applicant or Employee in cover letter or resume
Sex life or sexual orientation information.	As required by law or as long as necessary for a business purpose, whichever is longer.	Process health insurance claims Ensure equal access to retirement programs and fertility planning by same‑sex spouses Ensure equal family leave policies and insurance for transgender surgeries	YES, only if provided by Applicant or Employee in cover letter or resume

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.

Use of Personal and Sensitive Personal Information

We will not sell the personal information or sensitive personal information we collect. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. For more information on how we may use or disclose the personal information we collect, please see our Privacy Policy.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (See Exercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Phone: 503-278-7055
Emailing us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within 10 business days.

We endeavor to substantively respond to a verifiable consumer request within 45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your CCPA rights.