Scorpion Enterprises LLC

California Candidate Privacy Notice

Last updated: 8/21/26

This California Candidate Privacy Notice supplements the Scorpion Candidate Privacy Notice and applies solely to applicants, candidates, and prospective employees who are California residents. It is provided in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.

Where this notice conflicts with the general Candidate Privacy Notice with respect to California residents, this notice controls.

Categories of personal information we collect

In the preceding 12 months, we may collect the following categories of personal information from California candidates, as defined by the CCPA:

• Identifiers, such as name, postal address, email address, telephone number, and, where applicable, other similar identifiers.
• Personal records information (Cal. Civ. Code § 1798.80(e)), such as your employment and education history, professional qualifications, and information contained in your CV or resume.
• Professional or employment-related information, such as your work history, references, and details relevant to your suitability for a role.
• Education information, such as academic history and credentials not otherwise treated as publicly available.
• Internet or network activity information, such as interactions with our Greenhouse-hosted careers site and application portal.
• Audio and visual information, such as recordings, transcripts, and notes from virtual interviews, collected only where you have consented to the use of an AI-assisted note-taking tool (see “Sensitive personal information” and the AI-Assisted Recruiting Tools section of our general notice).
• Inferences drawn from the above to assess your suitability for a role.
• Sensitive personal information, as described in the section below.

We do not knowingly collect the personal information of applicants under the age of 16.

Sensitive personal information

The CCPA classifies certain personal information as “sensitive personal information.” From California candidates, we may collect:

• At the application stage: demographic information (such as race, ethnicity, veteran status, or disability status) that you voluntarily provide through Equal Employment Opportunity (EEO) or diversity self-identification forms. Providing this information is entirely optional. It is not used to make hiring decisions and is not shared with hiring managers in a manner that identifies you. Declining to provide it will not affect your application in any way.
• After a conditional offer of employment: your Social Security number, driver’s license, state identification card, or other government-issued identification, and information collected as part of a background or reference check, where permitted by law and conducted with appropriate notice and authorization.

We collect and use sensitive personal information only for the purposes permitted under the CCPA, including to perform the recruiting and (where applicable) onboarding functions described in this notice and to comply with our legal obligations. We do not use or disclose sensitive personal information for purposes beyond those permitted under the CCPA, and we do not use it to infer characteristics about you.

Sources of personal information

We collect personal information from the following sources: directly from you through our Greenhouse-hosted careers site; from employee referrals, recruiters, and recruiting events; from publicly available professional profiles (for example, LinkedIn); and, after a conditional offer, and only with your express written consent from a background-check provider acting on our behalf.

Purposes for collecting personal information

We collect and use California candidates’ personal information to:

• Evaluate, process, and respond to your application
• Communicate with you about your application and potential opportunities
• Assess your qualifications and suitability for a role
• Conduct, after a conditional offer, background and reference checks where permitted by law with your express written consent
• Maintain records of our recruiting activity
• Comply with applicable legal, regulatory, and recordkeeping obligations

Disclosure of personal information

In the preceding 12 months, we may have disclosed the categories of personal information above to service providers who perform recruiting related functions on our behalf, for example, our applicant tracking and careers site hosting provider (Greenhouse), a video-interviewing provider, an AI-assisted note-taking provider, and, after a conditional offer, a background-check provider. These parties are contractually required to use the information only to perform services for us and to protect it consistent with this notice.

Sale and sharing of personal information

Scorpion does not sell or share your personal information for cross-context behavioral advertising, as those terms are defined under the CCPA. We have not sold or shared California candidates’ personal information in the preceding 12 months.

SMS Privacy Notice

If you provide your mobile phone number and consent to receive text messages when applying for a position with Scorpion, we may contact you via SMS for recruiting-related purposes. These messages may include:

• Application status updates
• Interview scheduling and confirmations
• Reminders and follow-ups
• Offer-related communications

We do not use SMS messaging for marketing purposes, and we do not sell or share your mobile number or SMS consent with third parties for their marketing use.

SMS communications may be facilitated through third-party service providers (such as our texting platform, Grayscale by Paylocity), who process data on our behalf in accordance with our instructions and applicable privacy laws.

Please read the SMS Terms & Conditions here.

Retention

We retain California candidates’ personal information for as long as needed for the purposes described in this notice. If we do not employ you, we may retain your personal information for up to 7 years for legal, analytical, and system-administration purposes and to consider you for potential future roles, after which we may retain only a minimal record of your recruiting activity. If you are hired, we retain your information in accordance with applicable state and federal recordkeeping laws for the duration of your employment and any period required thereafter.

Your California privacy rights

Subject to certain exceptions, California candidates have the right to:

• Know / Access – request the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collecting it, and the categories of third parties to whom we disclose it.
• Delete – request that we delete personal information we have collected from you.
• Correct – request that we correct inaccurate personal information we maintain about you.
• Limit use of sensitive personal information – direct us to limit our use of your sensitive personal information to that which is necessary to perform the services reasonably expected. (Because we already use sensitive personal information only for permitted purposes, this right may have limited practical effect on how we process your data.)
• Opt out of sale/sharing – because we do not sell or share personal information, no opt-out is necessary; we honor opt-out preference signals where applicable.
• Non-discrimination / non-retaliation – you will not be subject to discrimination or retaliation for exercising any of these rights.

How to exercise your rights

You may submit a request by emailing our compliance team at [email protected]. We will verify your identity before fulfilling your request, and we may ask for additional information for verification purposes. You may use an authorized agent to submit a request on your behalf, subject to verification.

We will respond to verifiable requests consistent with the timeframes and requirements of the CCPA. Exercising these rights is free of charge, though we may charge a reasonable fee or decline a request that is manifestly unfounded or excessive, as permitted by law.

Contact us

If you have any questions, comments, or concerns about this notice or how Scorpion collects, uses, or processes your personal information, please contact our Privacy Team at [email protected].

We will not discriminate or retaliate against you for exercising any rights available to you under applicable California privacy law.