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Introduction & Policy Statement

Alta Resources Corp. prioritizes the protection of your privacy. We aim to transparently communicate the methods by which we collect, utilize, and disclose your personal information. Please be aware that Alta Resources retains the authority to amend, adjust, or update this Privacy Policy periodically. Any revisions will be communicated by publishing an updated version on our websites, accompanied by a modification of the “Effective Date” at the header of this Policy. In the event of significant changes, we will directly notify you. To stay informed about any modifications, we advise you to regularly review this Policy.

This Privacy Policy provides a comprehensive understanding of our data practices by elucidating the following key points: the specific categories of personal information collected, the diverse sources from which this information is obtained, the purposes guiding the utilization of your personal data, potential disclosure mechanisms, the duration for which your information is retained, an overview of your privacy rights along with guidance on their exercise, and the procedures governing any alterations to this Privacy Policy

The Categories of Personal Information We Collect

Employees

Personal Information Collection – Throughout the recruitment process, we gather information from you in relation to your application. The data we collect encompasses:

We may acquire information about you directly from you or from various sources, always ensuring it is permissible and in accordance with applicable law. This information may be gathered:

Who Will Have Access to Your Information

Typically, access to your Personal Information within Alta is limited to individuals who require it for the outlined purposes in this Privacy Notice. This includes individuals such as your potential future managers, direct colleagues, as well as personnel involved in recruitment, HR, and IT.

Alta Resources Corp. does not engage in the sale of your Personal Information, nor do we share it with third parties for cross-context behavioral advertising. However, your Personal Information may be disclosed in compliance with applicable laws and requirements, as outlined below:

California: Alta discloses your personal information and/or sensitive personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the California Privacy Rights Act (“CPRA”) and other applicable laws.

In addition, any supplementary third-party providers rendering employee benefits shall procure access to personal information solely upon the express consent and authorization of the employee in question.

Third Party Service Providers

Alta discloses your personal information to service providers and contractors only subject to written contracts in compliance with the CPRA and any other applicable law.

Hireright (US): Alta Resources uses Hireright to perform employee background checks in the United States locations. HireRight is a leading global provider of on-demand employment background checks, drug testing, Form I-9 and employment and education verifications.

100 Centerview Drive, Suite 300

Nashville, TN 37214

United States

Phone: (866) 521-6995

Ceridian (Global): Alta Resources securely stores employee data using Dayforce, Inc., previously known as Ceridian. Dayforce, Inc. is a reputable provider of human resources software and services, serving a diverse workforce spread across the United States, Canada, Europe, the Middle East, Africa (EMEA), and the Asia Pacific Japan (APJ) region. Dayforce, Inc.
3311 East Old Shakopee Road 
Minneapolis, MN 55425-1640
Phone: (952) 853 – 8100

In Addition:

Government or Administrative Agencies:

This may encompass, for instance:

• Internal Revenue Service for tax payment purposes.

•Employment Development Department, as necessary for state payroll taxes and in response to unemployment or state disability insurance claims.

• OSHA/CalOSHA for reporting work-related death or serious injury or illness.

• Department of Fair Employment and Housing to address employment charges.

• California Department of Industrial Relations for the resolution of workers’ compensation claims.

Public Disclosure: Alta may divulge your personal information to the public in scenarios such as press releases, where, for example, promotions or awards are announced. If you prefer not to have your personal information included in press releases, please contact the HR Department. It’s important to note that Alta refrains from disclosing sensitive personal information to the public.

Legal Obligations:

Your Personal Information may be disclosed in accordance with our legal obligations, including instances where it is necessary to comply with the law, regulations, contractual obligations, or respond to a court order, administrative or judicial process, such as a subpoena, government audit, or search warrant.

Public Bodies and Authorities:

We may disclose your Personal Information upon request from a governmental or regulatory entity or body, or when we have a good faith belief that such disclosure is essential to (1) comply with legal or regulatory requirements or fulfill legal processes; (2) prevent crime; (3) avert any terrorist activity or threat to national security; (4) safeguard the personal safety or well-being of Site users or any other individual.

Legal Proceedings:

Alta Resources Corp. reserves the right to disclose your Personal Information to the extent permitted by applicable law when it is necessary to establish, exercise, or defend against potential, threatened, or actual legal claims.

Vital Interests:

We may also disclose your Personal Information when deemed necessary to protect your vital interests or the vital interests of another person.

How Long We Keep Your Personal Information

Alta retains your personal information only for the duration necessary for the purpose for which it was collected, aligning with our record retention schedule. We will keep your personal data, in a format that allows us to identify you, no longer than required for the specific processing purpose. Storage beyond this period is solely for compliance with legal obligations, resolution of disputes, enforcement of agreements and rights, or when it is not technically and reasonably feasible to remove it. In cases where applicable, we endeavor to delete your personal data promptly upon request, within a reasonable timeframe.

Retention Criteria by Category: Consistent with Cal. Civ. Code §1798.100(a)(3), the criteria Alta uses to determine the retention period for each category of personal information are as follows: (a) application and candidate data for individuals not hired is retained based on the applicable statute of limitations for employment-related claims and Alta’s recruitment records-management criteria; (b) employment records for hired employees are retained for the duration of employment plus the period required to satisfy applicable tax, labor, and employment-law recordkeeping obligations; (c) background-check results are retained per Alta’s background-check vendor contract terms and applicable consumer-report recordkeeping laws; and (d) sensitive identifiers (e.g., Social Security, driver’s license, state ID, or passport numbers) are retained only as long as necessary for the purposes described in this Notice, after which they are securely destroyed.

Protecting Your Data

In the context of safeguarding your Personal Information, Alta Resources Corp. implements robust security measures to prevent unlawful or unauthorized processing, as well as accidental loss or damage to the data. These measures are designed to maintain the confidentiality, integrity, availability, and overall security of your Personal Information.

Alta has established written security management policies and procedures, which serve to prevent, detect, contain, and correct any breaches or violations of the protective measures in place. These policies and procedures allocate specific data security responsibilities and accountabilities to designated individuals. Furthermore, they incorporate a risk management program that includes regular risk assessments, providing a comprehensive framework of controls to ensure the safeguarding of your Personal Information.

When engaging third-party service providers who may access your Personal Information, Alta insists on contractual agreements that mandate similar security controls. This ensures that the third parties adhere to stringent security measures consistent with Alta’s commitment to protecting your information.

The Purposes for Which We Use Your Information

Alta Resources Corp. will process your Personal Information, including Sensitive Personal Information where permitted, for our business purposes, specifically focusing on recruitment, management, and planning activities. This encompasses:

Alta will process Personal Information when required by law, deemed necessary for the potential employment contract, or when there is a legitimate interest that is not outweighed by your data protection interests or fundamental rights and freedoms. We take into careful consideration the safeguards in place to protect your privacy.

Sensitive Personal Information will be processed by Alta when necessary to fulfill a legal obligation or to exercise specific rights, either yours or those of Alta Resources, concerning your prospective employment.

In cases where local law mandates or for new or additional purposes, Alta will seek your consent to process your Personal Information. For instance, obtaining your prior consent may be required under applicable law for specific types of processing related to Sensitive Personal Information or Personal Information concerning criminal offenses and convictions. This approach ensures that your privacy rights are respected and upheld throughout the processing of your information.

Legal Reason for Use

To assess your suitability for employment for the role for which you are applying (excluding background checks), as well as future roles that may become available, Alta Resources conducts necessary background checks. This process is essential for Alta’s legitimate interests to ensure that it recruits the appropriate employees. Additionally, it involves taking steps prior to entering an employment contract with you, particularly when you are being considered for employment. Verifying eligibility to work involves actions before entering into an employment contract, aligning with Alta’s legitimate interests in adherence to relevant immigration and/or employment laws and regulations. Managing and administrating your application, as well as facilitating communication, are necessary steps for Alta to secure suitable employees. Effective communication within the organization and with you is also crucial for maintaining an efficient recruitment process. Compliance with or monitoring applicable laws and regulations is essential for fulfilling Alta’s legal obligations as a business entity and safeguarding the rights and interests of Alta, its employees, candidates, and others.

Alta processes employees’ health information to fulfill its legal obligations, which include accommodating disabilities, conducting direct threat analyses, managing workers’ compensation, undertaking occupational health surveillance, ensuring compliance with health and safety regulations, conducting fitness-for-duty examinations, administering leaves of absence and sick time, facilitating wellness programs, and responding to medical emergencies. This Privacy Policy excludes health information governed by specific healthcare privacy laws, such as the Health Insurance Portability and Accountability Act (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH Act), or California’s Confidentiality of Medical Information Act (CMIA).

Regarding the use of employees’ protected categories of information, Alta gathers data concerning race, age, national origin, disability, sex, and veteran status to meet legal obligations, including reporting requirements under the Federal Equal Employment Opportunity Act, the Federal Office of Contracting Compliance Programs for government contractors, and California’s Fair Employment and Housing Act. Disability status information ensures that employees receive necessary assistance during emergencies. For diversity and inclusion programs, characteristics such as age, sex, race, disability, and veteran status are collected and used for analytics. The collection of military and veteran status information aids compliance with leave requirements and tax purposes. Other characteristics, such as age, religion, pregnancy, childbirth, breastfeeding, marital status, familial status, and protected classifications, are collected for specific purposes including birthday celebrations, identity verification, accommodations under applicable law, I-9 documentation, and Alta events. Alta emphasizes the voluntary nature of collecting personal information about membership in protected categories, except where mandated by law, and ensures its use strictly complies with applicable laws and regulations.

Your Privacy Rights and How to Exercise Them

Your California Privacy Rights (CPRA)

Subject to applicable law, Employees have the following rights:

Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal

information collected in the preceding 12 months or at your option since January 1, 2022. Please note that the CPRA’s right to obtain copies does not grant a right to the whole of any document that contains personal

information, but only to copies of “specific pieces” of personal information. There may be some specific

information about you that we are not permitted by law to provide to you because of legal restrictions or because the information is used for security purposes, such as information collected in an internal investigation. You may make these requests up to twice in a 12-month period. Moreover, Employees have a right to know categories of information collected, the sources of personal information, our purpose for collecting and using personal information, and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients. This information is provided above. Alta does not always track individualized sources or recipients.

Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Alta. Certain information that we hold about you may not be deleted. We are not permitted to delete information that we need in order to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and our Alta.

Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal

information maintained by Alta, taking into account the nature of the personal information and the purposes of processing the personal information.

Right to Opt Out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for cross-context advertising. As noted above, Alta does not sell personal information or disclose personal information for cross-context advertising.

Right to Limit Processing of Sensitive Personal Information: You have the right to tell us not to process sensitive

personal information except for the purpose for which it was originally collected. Sensitive personal information includes the following categories of information described above: personal information, characteristics of protected classifications, sensitive identifiers, health information, biometrics, religion, sex life, sexual orientation, personal communications, financial account information, neural data, and log in credentials. We describe the purposes for which we collect this information above and we do not process this information for other purposes.

Alta is committed to not discriminating against you for exercising your rights. We diligently respond to all requests from individuals seeking to exercise their data protection rights, adhering to applicable data protection laws. It is important to note that Alta may deny or limit compliance with all or part of your request if doing so would violate another person’s rights or is otherwise permitted by applicable law.

Before addressing a request, we reserve the right to verify and authenticate your identity along with the relevant information connected to your request. In this process, Alta may request the following information: (a) First, Middle (if available), and Last Name; (b) Physical Address; (c) Month/Year of Birth; (d) Valid Email Address; and (e) Valid Telephone Number

Additional CPRA Protections (Updated 2025–2026)

Personal Information Processed by AI Systems: Consistent with Assembly Bill 1008 (effective January 1, 2025), Alta confirms that “personal information” under the CPRA can exist in any format, including information generated, processed, or output by artificial intelligence systems capable of outputting personal information. Where Alta uses AI-enabled tools in recruitment, workforce management, or related processing, information those tools generate about you is treated as personal information subject to this Notice.

Automated Decision-Making Technology (ADMT): Where Alta uses Automated Decision-Making Technology to make or facilitate a significant decision about you — such as decisions concerning hiring, promotion, discipline, or termination — Alta will, consistent with the California Privacy Protection Agency’s ADMT, risk assessment, and cybersecurity audit regulations (effective January 1, 2026, with ADMT-specific obligations phasing in beginning January 1, 2027), provide you with notice of that use where required and, subject to applicable exceptions, the right to opt out of or request information about that use. To exercise this right or ask whether ADMT applies to a decision about you, contact our Data Protection Officer at [email protected]. Ahead of the ADMT regulations’ phased compliance dates (beginning January 1, 2027), Alta will provide a pre-use notice identifying the specific ADMT tool, the purpose for which it is used, and how to exercise the right to opt out or request human review of the decision, and will offer an appeal/human-review mechanism for significant decisions made or facilitated by ADMT.

Data Broker Status: Alta Resources is not a registered data broker under the California Delete Act (SB 362) and does not sell personal information to third parties for data-broker purposes. The Delete Act’s centralized deletion mechanism (“DROP”) accordingly does not apply to Alta’s processing of your personal information under this Notice.

How to Exercise Your Rights?

If, at any time, you have questions or concerns about the operation of this Notice or believe that we have not adhered to this Notice, please email our Data Protection Officer: [email protected]

Additional Ways to Reach Us: Consistent with Cal. Civ. Code §1798.130(a)(1), you may also submit a request by mail addressed to: Alta Resources Corp., Attn: Data Protection Officer, 120 N Commercial St, Neenah, Wisconsin 54956, US, or by calling our privacy line at 877.464.2582.

Request Confirmation and Response Timeframe: We will confirm receipt of your verifiable request within 10 business days and will describe our process for responding to it. We will respond to your request within 45 days of receipt; if needed, we may extend this period once by an additional 45 days (90 days total), in which case we will notify you of the extension and the reason for it within the initial 45-day period.

Authorized Agent: You may designate an authorized agent to submit a request on your behalf. To do so, the authorized agent must provide proof of your written authorization (or, where permitted, other reasonably reliable evidence of authorization), and we may still require you to verify your own identity directly or confirm the authorization directly with us before we complete the request.

Accessibility: If you need this Notice in an alternative format due to a disability, please contact our Data Protection Officer at [email protected] and we will provide it in a reasonably accessible format.

FOR MORE INFORMATION

For questions or concerns about Alta’s privacy policies and practices, please contact our Data Protection Officer: [email protected]

Changes to this Policy

Alta Resources Corp. reserves the right to amend this Notice, with changes taking effect immediately upon publication. Substantial modifications will be highlighted or communicated to you via email.