Hoyu Workforce Candidate Privacy Notice

Our Commitment to Privacy

Hoyu America Co., (“Hoyu,” “we,” or “us”) has developed and implemented this privacy notice (“Candidate Privacy Notice”) to demonstrate its commitment to privacy for individuals seeking to become a member of Hoyu’s workforce. This Candidate Privacy Notice is designed to assist workforce candidates in understanding how we collect, use, share, and safeguard personal information as part of the candidacy process.

To Whom This Candidate Privacy Notice Applies

This Candidate Privacy Notice applies to candidates to become workforce members of Hoyu.  Our privacy practices with respect to personal information collected in other contexts, including visiting the Hoyu Website, can be found in our Hoyu America Co. Privacy Policy.

How We Define Personal Information

Personal information (sometimes called “personal data”) is a broadly defined term whose legal definition varies across jurisdictions. When used in this Candidate Privacy Notice, personal information includes information that is reasonably capable of identifying a particular individual in connection with their application and consideration for employment.  Personal information does not include information that cannot reasonably be used to infer information about or otherwise be linked to a particular individual or household. We may use personal information to create deidentified or aggregated consumer information that we may use without restriction in accordance with applicable law.

How We Collect and Disclose Candidate Personal Information

The personal information we collect depends on the nature and context of your interaction with Hoyu. For example, our collection practices will vary depend on whether you have submitted a resume or submitted your application through a staffing or recruiting agency. It may also depend on the nature of the position for which you are seeking employment, the physical location of work, and other factors.

To make it easier to read and understand our policy, we have presented the relevant information in a chart explaining our collection, use, and disclosure practices related to workforce member candidates.

Human Resources Service Providers: When we refer to Human Resources Service Providers, we mean those persons or entities who assist in providing human resources and workforce management services, including background check providers, human resources software services providers, insurance providers, employee payment and benefits providers, governmental entities, and similar entities.

Business Operations Services Providers: When we refer to Business Operations Services Providers, we mean those persons or entities with whom we have a relationship to provide business operations services and support to Hoyu. These providers may include:

• IT Operations Providers: Cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.
• Professional Service Providers. Including lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.

Additional Disclosures

We may also disclose any personal information to the following:

• Affiliates. With our affiliates, including our parent company, subsidiaries, joint venturers, or other companies that we control or that are under common control with us, including our parent company, Hoyu Co. Ltd.
• Legally Required Parties. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
• Reorganization. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
• Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it.

In addition, we may collect personal information from any other person or entity with whom you provide a reference, including past employers, personal references, former colleagues, and others.

How We Use Candidate Personal Information

We use the personal information we collect as part of the candidate process:

• To Process Employment Applications and Onboard New Hires: We collect most personal information to evaluate your candidacy, including to open and maintain candidate records, communicate with you, conduct employment related background screening and checks, and evaluate your application.
• For Diversity and Equal Opportunity Monitoring: Where permitted by law, you have the option to provide certain sensitive personal information, such as race or ethnic origin, for the purposes of equal opportunities monitoring. If you decide not to provide this information, your application will not be prejudiced. You may also tell us if you have a disability, so that we can make appropriate arrangements for you to attend our offices and/or participate in an interview.
• To Maintain Security at Our Premises: If you attend in-person interviews at our offices or facilities, we may collect information related to your access to our building. This may include data related to your use of security control systems, audio and video captured on security cameras, and visitor logging information.
• To Conduct Candidate Evaluations: We collect and review your personal information from multiple sources to assess your suitability for employment or work with Hoyu.  This may include obtaining pre-employment background checks.
• For Onboarding: We may collect personal information necessary for employee onboarding purposes. We will provide you with additional privacy notices at that time.
• Required Disclosures: To comply with applicable legal and regulatory requests and obligations (including investigations).
• Legal Defense: To establish or defend legal claims and allegations.
• Security Purposes: For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct.
• Professional Advice: To seek advice from lawyers, auditors and other professional advisers.
• For Similar Purposes: When necessary or advisable we may process your personal information for purposes similar to those mentioned above, and consistent with the purpose for which you provided your personal information.

Retention of Personal Information

We will retain personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider: (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements. In some circumstances, you may ask us to delete your personal information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How We Protect Personal Information

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Periodically, our operations and business practices are reviewed for compliance with policies and procedures governing the security, confidentiality, and quality of our information. Our corporate values, ethical standards, policies, and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information and limit the use and disclosure of such information to authorized persons, processes, and transactions.

Children’s Personal Information

We do not consider candidates for employment under the legal working age for the jurisdiction in which employment is to be offered. We do not knowingly collect or process the personal information of individuals under the age of 18. If you believe that a child under 18 may have provided us their personal information, please contact us at  hr@zz.us.hoyu.com

Your Privacy Choices

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include:

• Access. The right to know (or confirm) what personal information a business has collected about you.
• Deletion. The right to request that a business delete personal information it has collected from you, subject to certain exception.
• Correction. The right to request correction of inaccurate personal information maintained by the business.
• Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt-out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt-out of the use of personal information for targeted advertising purposes.
• Limitation. The right to limit a business’s use or disclosure of certain information, typically sensitive personal information. However, Hoyu does not use or disclose sensitive personal information for any purpose other than for permissible purposes under California law.
• Opt-out of Profiling: The right to opt- out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.

Hoyu will honor the privacy rights afforded to individuals in accordance with applicable law.

You may make a request at any time to exercise your privacy rights listed above by using our Privacy Portal or emailing us at official_contact@color.us.hoyu.com.  We will respond to your request within a reasonable period of time (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.

International Data Transfers

Hoyu is based in the United States and we operate our website and portals from there. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. By submitting personal information to us, including by accessing our website and portals, you understand that we may process, store, and transfer your personal information in and to jurisdictions foreign to you, including the United States. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy laws.

Updates to Our Candidate Privacy Notice

We may update this Workforce Candidate Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the Notice and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).

Contacting Hoyu

To ask questions or comment about this Candidate Privacy Notice and our privacy practices, contact us at hr@zz.us.hoyu.com.

Supplemental Notice for Residents of California

This section applies to residents of the State of California in addition to all other applicable rights and information contained in this Policy. The California Consumer Privacy Act requires that we describe the personal information we collect, disclose, and sale/share based on certain defined categories. Please see the “How We Collect and Disclose Candidate Personal Information” section above, for this description. We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

Exercising Your CCPA Rights

California Residents have certain rights under the CCPA. For information on how to exercise these rights, please see below.

Submitting Access, Deletion, and Correction Requests

To make an access, deletion, correction, or limitation request, please use our Privacy Portal, email us at hr@zz.us.hoyu.com, or call us at [TELEPHONE NUMBER].

After we receive your request, to ensure the security of the information we store and consumers’ privacy, we will verify that you are appropriately affiliated with the subject of the request, either as the consumer or as an authorized agent or guardian of the consumer. We may ask you to provide a few pieces of information to confirm your identity in our records.

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf and we may deny a request from an agent on your behalf if we cannot verify that they have been authorized by you to act on your behalf. Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided a power of attorney under the California Probate Code.

Limiting the Use of Your Sensitive Personal Information

Californian’s have the right to limit a business’s use or disclosure of sensitive personal information. However, Hoyu does not use or disclose sensitive personal information for any purpose other than for permissible purposes under the CCPA.

Opting Out of the Sale/Share of Your Personal Information

Hoyu does not sell or share personal information related to the workforce member candidacy process. Please review the Hoyu Privacy Policy for more information about opt-out rights for website visitors.

Contact Us Regarding Your Privacy Rights

If you would like additional information related to your privacy, please email us at hr@zz.us.hoyu.com.  Please submit your CCPA rights requests using the methods described above.