Employee Privacy Notice

Updated: January 1, 2023

QuinStreet, Inc. California Employee Privacy Notice

This Employment Privacy Notification (“Notice”) is intended to provide employees of QuinStreet, Inc.,
who are California residents with the required notice under the California Consumer Privacy Act
(“CCPA”) (as amended by the California Privacy Rights Act (“CPRA”)).

NOTICE AT COLLECTION: QuinStreet collects the Personal Information identified under “Personal
Information We Collect About You” for the purposes described under “Purpose for Collecting Your
Personal Information.” For more information on your privacy rights, please see “Your California Privacy
Rights” below.

1. Updates
This Notice will be updated at least once every twelve (12) months to reflect changes in our business,
legal, or regulatory obligations. Changes to this Notice will be effective from the date indicated in the
top right corner.

2. Definitions
2.1 “Personal Information” has the meaning as defined in the CCPA (as amended by the CPRA), which
includes information that is collected by QuinStreet in the course of employment related purposes and
encompasses any information that identifies, relates to, describes, is capable of being associated with,
or could reasonably be linked, directly or indirectly, with you or your household.
2.2 “Process” “Processed”, or “Processing” means an operation or set of operations which are
performed on Personal Information, whether by automated means, such as collection, recording,
organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or combination, restriction,
erasure or destruction of Personal Information.
2.3 “Employees”, “Employee” or “You” means an identified or identifiable natural person who is a
California resident and who is acting a QuinStreet job applicant, employee or contractor. In this context,
“job applicant” is any person who has submitted their candidacy to QuinStreet; “employee” is any
person who is employed at QuinStreet as a full-or part-time employee or temporary worker, and
“contractor” is a natural person who provides any service to QuinStreet pursuant to a written contract.

3. Personal Information QuinStreet May Collect About You
QuinStreet may collect the following categories of Personal Information from you as an Employee:
3.1 Identifiers Including real name, alias, postal address, unique personal identifiers, email, account name, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.
3.2 Characteristics of Protected Classifications Under California or Federal Law Including race, skin color, national origin, religion (includes religious dress or grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical conditions (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.
3.3 Internet or Other Electronic Network Activity Information Including browsing history, search history, application access location and information regarding an employee’s interaction with an internet website, application or advertisement, time and geolocation data related to use of an internet website, application or physical access to a QuinStreet office location
3.4 Visual and Audio Information Including information captured from video, audio, systems, or other forms of monitoring or surveillance, including data collection from CCTV images.
3.5 Professional or Employment-related Information Including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; information from employee's expenses; browsing and search history; payroll and benefits related data; internal and external contact information.
3.6 Biometric Information Including imagery of your fingerprint, face, and voice recordings
3.7 Education Information Including information about an employee’s educational background, such as education records, report cards, and transcripts that is not publicly available.
3.8 Inferences Including any information drawn from any of the Personal Information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
3.9 Sensitive Personal Information Including social security number, driver’s license number, passport number, racial or ethnic origin, religion, sexual orientation, and other information related to health.
4. Purpose for Collecting Your Personal Information
The Personal Information QuinStreet may have collected in Section 3 may be used for:
4.1 To Recruit Employees Including conducting employment related background screening and checks.
4.2 To Administer Benefits Including medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.
4.3 To Pay and Reimburse for Expenses Including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.
4.4 To Conduct Performance-Related Reviews Including performance appraisals, career planning, skills monitoring, job moves, promotions and staff restructuring.
4.5 To Monitor Work-Related Licenses and Credentials Including provisioning software licenses for use in the source of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.
4.6 To Provide Our Employees with Human Resources Management Services Including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration
4.7 To Administer International Assignments Including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements and populating the International Mobility global system.
4.8 To Maintain Your Contact Information Including altering your details across relevant entities within the Lever group of companies (for example personal, other employment and transferring roles).
4.9 To Assist You in Case of Emergency Including maintenance of contact details for you, and your dependents in case of your personal or business emergency.
4.10 To Monitor Eligibility to Work in the U.S. Including the monitoring and ensuring of employee’s ability to work in the U.S.
4.11 To Conduct Healthcare-Related Services Including conducting pre-employment and employmentrelated medical screenings for return-to-work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.
4.12 To Facilitate Better Working Environment Includes conducting staff surveys, providing senior management information about other employees, and conducting training.
4.13 To Ensure a Safe and Efficient Working Environment Includes QuinStreet actions relating to disciplinary actions, and code of conduct processes and investigations.
4.14 To Maintain Security on QuinStreet Websites and Internet Connected Assets Includes hosting and maintenance of computer systems and infrastructure; management of Lever’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
4.15 To Comply with Applicable Law or Regulatory Requirements Including legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security, and Environmental reporting.

5. Information Retention
QuinStreet will keep your Personal Information only for as long as necessary to fulfill the purposes for
which it was collected, including for the purposes of satisfying any legal or reporting requirements. To
determine the appropriate retention period for Personal Information, QuinStreet considers the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure of the information; the purposes for which the information is used; whether those purposes can be achieved through other means; and the applicable legal requirements.

Once retention of your Personal Information is no longer necessary for the purposes outlined in this
Privacy Notice, QuinStreet will either delete or de-identify it. If this is not possible (for example, because
the information has been stored in backup archives), it will be isolated from further processing until
deletion or de-identification is practicable.

6. Your California Privacy Rights
If you are a California resident, you may take advantage of the following privacy rights:

  • Right to Know: You have the right to know what Personal Information QuinStreet has collected
    about you, including the categories of Personal Information, the categories of sources from which
    the Personal Information is collected, the business or commercial purpose for collecting, selling, or
    sharing Personal Information, the categories of third parties to whom the Personal Information has
    been disclosed, and the specific pieces of Personal Information collected about you.
  • Right to Delete: You may request that the Personal Information collected from or about you be
    deleted. Note that there are cases where QuinStreet may not be able to fully address your request,
    such as to perform a contract, to detect and protect against fraudulent and illegal activity, to
    maintain data for internal purposes, to comply with a legal obligation or to preserve or exercise legal
  • Right to Correct: You have the right to correct inaccurate Personal Information maintained
    about you, subject to appropriate verification.

Right to Non-Discrimination. You have a right not to receive discriminatory treatment from QuinStreet
for exercising your privacy rights conferred by law.

Use and Disclosure of Sensitive Personal Information. To the extent that QuinStreet collects, uses or
shares “sensitive personal information” as that term is defined in applicable California privacy laws, the
use or disclosure of such information is permitted for business purposes only.

How to Submit a Request. To take advantage of your Right to Know, Delete, or Correct under California
law, please follow the corresponding links below. QuinStreet may request certain information to verify
your identity before responding to your request.

You may also email QuinStreet_EBC@QuinStreet.comto take advantage of your Right to Know, Delete,
or Correct requests under California law.

Authorized Agent Requests. You may authorize someone to make a privacy rights request on your
behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them
to act on your behalf. QuinStreet retains the right to request confirmation directly from you confirming
that the agent is authorized to make such a request, or to request additional information to confirm the
agent’s identity.

Sale and sharing of personal information. QuinStreet does not “sell” or “share” (as such terms are
defined in the CCPA) Personal Information and has not “sold” or “shared” Personal Information in the
past twelve (12) months.

6. Contact
If you have questions or concerns about this Privacy Notice please contact QuinStreet’s Employee
Benefits and Compliance at QuinStreet_EBC@QuinStreet.com.

You can also write to QuinStreet at the following address:
QuinStreet Employee Benefits
(CA Privacy Notice Request)
950 Tower Lane, Floor 6
Foster City, CA 94404

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