Privacy Notice

Protecting Your Personal Information

UKG Inc. and its respective affiliates (collectively, “UKG”, “we” and/or “us”) are committed to protecting the privacy of the individuals (“visitors” and/or “you”) who visit our website and subpages located at https://www.ukg.com/ (the “Site”).

SCOPE

This Website Privacy Notice (“Website Notice”) describes UKG’s privacy practices in connection with your use of the Site. We provide information about the choices you have regarding the collection or use of your personal information including similar terms as defined by various jurisdictions, and the rights provided to you, including the ability to access or update your personal information. This Website Notice does not cover UKG’s privacy practices for:

• UKG products and services, accessible via the Site or otherwise, and whether used by UKG’s customers, partners or end users; or
• This website Privacy Notice does not apply to eVAULT, which has its own Privacy Notice.
• For more information about biometric data and UKG’s timekeeping devices click here.
• Children and/or Minors. Our Site is neither designed nor intended for any visitors under 18 years of age. If you have any reason to believe that a visitor to our Site is under 18 years old, please contact us at [email protected] and we will endeavor to delete the information from our databases.

Please refer to our ESG Program – Privacy and Data Protection page to learn more about UKG's commitment to privacy.

What is Personal Information?

The Website Notice applies to personal information collected from visitors to the Site. For purposes of this Website Notice, “personal information” means information collected by UKG relating to an identified or identifiable natural person and includes similar terms as defined by various jurisdictions.

Links to Non-UKG Websites

For your convenience, the Site may contain links to third-party websites and/or information. When you access those links, you leave UKG’s Site and are redirected to a third-party website. UKG does not control third-party websites, thus the privacy practices of third parties might differ from UKG’s privacy practices. We do not endorse or make any representations about third-party websites. When you share personal information with third-party websites, the third-party processing is not covered by this Website Notice. We encourage you to review the privacy policy of any website or company before sharing personal information.

HOW UKG COLLECTS YOUR PERSONAL INFORMATION

Sources of Personal information and Personal Information we Collect:

UKG collects personal information from several different sources, including:

• Directly from a website visitor including job applicants;
• From service providers or other third parties; and
• Automatically from a website visitor’s visit or activity on our Site.

Please review each of the sections below to learn more about how UKG collects personal information, and what personal information is collected.

How We Collect Personal Information

UKG collects personal information when you visit our Site and when you choose to provide personal information. For example, we collect information when you contact us via our Site, provide your email, phone number or other similar contact information, such as the information that you provide when you sign up for a webinar. Job candidates who complete an application for employment with UKG or create a profile on this website may also provide credentials and other information relevant to the job application.

Examples of Personal Information We Collect

Source	Data Elements	How/Purpose
Personal information collected from a visitor to our Site may include:	Name; Company; Job Title; Address; Phone Number; and Email Address.	To fulfill the purpose(s) for which the information was collected or provided, including to communicate with you and respond to your inquiries and requests   Lawful Basis: Legitimate Interest
Third Parties or Publicly Available Sources (including purchased business contact information)	First name Last name Business Email Telephone number Company name Job level Functional role Business street address Online identifier Employment history	We use this data for our internal customer analytics, to identify prospective customer marketing opportunities, and to improve the relevance of our Site content and our advertising.  We may collect or receive personal information from third parties including from our affiliates, marketing companies, job posting websites and recruiting firms. This data may be licensed by third parties or available publicly.    We collect business contact information for account management purposes related to the use of UKG software-as-a-service applications or professional services.    Lawful Basis: Legitimate Interest
Website Information	First name Last name Business Email Telephone number Company name Job level Functional role Street address A photo* Social media profiles* Areas of expertise*    * Some areas of the Website, including UKG Community, require you to create a user account. As part of your user account, you may choose to provide us with additional information.	Analytics Information    Lawful Basis: Legitimate Interest
UKG Events Information	First name Last name Business Email Telephone number Company name Emergency contact (in some instances) Dietary preferences (in some instances) Health and safety information (in some instances) Billing information (such as billing name, billing address, and credit card number)	If you register to attend a UKG-sponsored Event, we may require certain data    Lawful Basis: Performance of Contract & Legitimate Interest
Information Collected Directly from Social Media Features	IP address	Our Site may include social media features, such as video links and other functionality to demonstrate your interest in our Site and other materials and may set a cookie to enable such functionality. This functionality may be hosted by a third party or hosted directly on our Site. When provided or hosted by a third party, your use and interactions with these features is at your discretion and is governed by the privacy policy of the companies providing them.    Lawful Basis: Legitimate Interest
Customer Account Management Information	First name Last name Business Email Telephone number Company name Job level Functional role Business street address Online identifier	We collect business contact information for account management purposes related to the use of UKG software-as-a-service applications or professional services.  Lawful Basis: Legitimate Interest
Analytics Information	IP address Mobile Phone Number Unique Verification Identification Number Email address	Our Site may record information concerning how often you use the application, the events that occur within the application, aggregated usage, performance data, your IP address. We do not link the information we store within the analytics software to any personal information you submit within the Site.  If you use certain systems provided by UKG, we will collect data from you to enable multifactor authentication, such as mobile number, email address, or unique verification identifier.  Lawful Basis: Legitimate Interest

Cookies and Other Similar Technologies

Like many websites, UKG uses cookies and similar tracking technologies (including for analytics, functionality, advertising, and other purposes). For more information about the technologies, we use and how you can control these technologies, please see our Cookie Notice.

Other Information

If UKG collects any other personal information from you, we will explain which personal information is collected and the purpose for its collection.

HOW UKG USES PERSONAL INFORMATION

Why We Use Your Personal Information:

UKG relies on lawful bases, such as Performance of Contract or Legitimate Interest. Additionally, we may process personal information for the following purposes:

• To fulfill the purpose(s) for which the information was collected or provided, including to communicate with you and respond to your inquiries and requests;
• To improve our Site, products and services, through testing, research, analysis and product development;
• To market, advertise, and promote our products and services, such as to make suggestions and recommendations to you about products or services that may be of interest to you;
• To provide support and information about our product and services via virtual assistant, also known as chatbot, available 24/7 on our Sites;
• To provide training related to the products and services, such as making available training materials or events (whether in-person or online) for which we may use your personal information to provide notices and information regarding such training and events;
• For security, audit, internal investigation, and fraud prevention purposes, such as to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity, and availability of your personal information; to allow only the appropriate use of your personal information; to identify any fraudulent, harmful, unauthorized, unethical or illegal activity;
• To manage litigation, such as in connection with establishing, exercising, or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;
• To improve the content and format of our Site by using cookies and other similar technologies, such as to measure the preferences of our Site visitors, analyze trends, administer the Site, analyze use of the Site, and to gather demographic information about visitors to the Site;
• To allow us to better understand the functionality of our mobile applications, though we do not link the usage information we collect through the mobile applications to any personal information you submit within the mobile application;
• For other purposes for you have provided consent;
• To aggregate or deidentify your personal information so that the information can no longer be linked to you or your device and use and share such data for any business purpose in accordance with applicable law; and
• To comply with all applicable legal obligations, such as to comply with subpoenas and other court orders to process data where we have determined there is a legal requirement to do so.

WHEN UKG DISCLOSES YOUR PERSONAL INFORMATION

Please note, UKG does not sell personal information to third parties. The term “sell” as defined by applicable laws, means disclosure of personal information to third parties for monetary or other valuable consideration.

Please review each of the sections below to learn more about how we may share your personal information.

Affiliates:

We may disclose your personal information to our Affiliates in order to facilitate delivery of a product or service or complete a task that you requested.

Third Parties (Vendors/Service Providers):

We may engage with third parties (vendors and/or service providers) to facilitate delivery of a product or service (or perform certain functions such as enhancing and/or delivering our product and service offerings); complete a task that you requested; provide training; conduct marketing and advertising; operate, secure, and optimize the Site; and coordinate and work with our partners.

We have contracts with such third parties to perform certain functions on our behalf, and only at our direction. These third parties are bound by agreements that contain confidentiality and other data protection terms designed to ensure the third parties only use your personal information to the extent necessary to provide these contracted services in accordance with our instructions (and for the purposes we disclose).

UKG may use support for marketing purposes, such as managing email campaigns. In such circumstances, UKG is the data controller, and a virtual assistant (chatbot) acts as a processor. Data Protection Agreements are in place to ensure the privacy and use of your data are in accordance with this Notice.

Additional Disclosures

We may disclose your personal information as necessary to:

• To provide customer service or technical support regarding training or webinars for which you register or attend;
• For our administration, and business operation purposes and to keep a record of your relationship with us;
• Comply with the law or with legal obligations, such as with law enforcement officials, government authorities or other third parties in response to a lawful request for information by a competent authority, if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process, including to meet national security or law enforcement requirements;
• To manage litigation and conduct internal audits and investigations, such as to protect and defend our rights and property, investigate fraudulent or illegal activity, and conduct internal financial, security, or other audits;
• Protect against misuse or unauthorized use of our Site, products, and services;
• Protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to use another’s identity, information about you may be disclosed as part of any investigation into your actions)
• In connection with, or during the negotiation of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or to another company, including the transfer of contact information and data of customers, partners, and end users;
• In an aggregated and de-identified or anonymized form; and
• When we have your consent to share the information.

Other than as stated in this Website Notice, we will endeavor not to release your personal information to unknown or unaffiliated third parties, and we will not cross-reference your personal information with that of any other customer or entity.

TRANSFERRING PERSONAL INFORMATION

International Transfers

UKG agrees it will use the Standard Contractual Clauses (“SCCs”) or the UK International Data Transfer Agreement for UKG transfers to third-party subprocessors subject to cross border mechanisms for transfers between UKG entities.

This practice complies with European requirements for transfers or processing of personal information by UKG outside the EEA, Switzerland, and the UK or in a jurisdiction other than the EEA, Switzerland, UK or other European Commission-approved countries providing ‘adequate’ data protection.

To learn more about how UKG complies with the Schrems II caselaw, please refer to UKG’s Transfer Risk and Impact Statement.

Data Privacy Framework

UKG complies with the EU-U.S. and the Swiss-US Data Privacy Framework as well as the UK-U.S. Data Privacy Framework (collectively, the "Data Privacy Framework") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom and/or Switzerland, as applicable. UKG has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles with respect to such information. If there is any conflict between the terms in this notice and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit the Data Privacy Framework website.

Data processed: UKG provides HR management tools that our customers use for their workforce. In providing these tools, UKG processes data our customers submit to our services or instruct us to process on their behalf. While UKG’s customers decide what data is processed, it typically includes information about their employees such as contact information, scheduling, and pay slips. Purposes of data processing: UKG processes data submitted by customers for the purpose of providing UKG’s online services to our customers. To fulfill these purposes, UKG may access the data to provide the services, to correct and address technical or service problems, to respond to customer support matters, or to follow customer instructions who submitted the data, in response to contractual requirements or for security monitoring.

Inquiries and complaints: If you believe UKG maintains your personal data in one of the services within the scope of our Data Privacy Framework certification, you may direct any inquiries or complaints concerning our Data Privacy Framework compliance to [email protected]. UKG will respond within 45 days. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. If neither UKG nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Data Privacy Framework Panel. For more information on this option, please see Annex I of the EU-U.S. Data Privacy Framework Principles.

Third parties who may receive personal data: UKG uses a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers offer various services, including data storage services. These third-parties may access, process, or store personal data in the course of providing their services. UKG maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Data Privacy Framework obligations, including the onward transfer provisions, and UKG remains responsible and liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

Your rights to access, to limit use, and to limit disclosure: EU individuals and Swiss individuals have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Data Privacy Framework self-certification, UKG has committed to respect those rights. Except for MyPeopleDoc Employee Vault and Immedis Tax Services, UKG personnel have limited ability to access data our customers submit to our services. If you wish to request access, or to limit use, or to limit disclosure, please provide the name of the customer who submitted your data to our services. We will refer your request to that customer and will support them as needed in responding to your request.

U.S. Federal Trade Commission enforcement: UKG’s commitments under the Data Privacy Framework are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Compelled disclosure: UKG may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. UKG maintains transparency reports accordingly.

APEC

UKG’s privacy practices, described in this Website Notice, comply with the APEC Cross Border Privacy Rules System (CBPR). The APEC CBPR system provides a framework for organizations to ensure the protection of Personal Information transferred among participating APEC economies. More information about the APEC framework can be found here.

RETAINING PERSONAL INFORMATION

UKG will only retain personal information for the length of time necessary to fulfill the purpose(s) for which the information was collected or as required or permitted by applicable laws, (including the resolution of disputes) and in accordance with our customer contracts.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require your personal information, we will either delete or deidentify it or, if this is not possible, we will securely store it in accordance with this Website Notice and cease use of the personal information until deletion is possible. If we deidentify your personal information (so that it is no longer associated with you), we may retain this information for longer periods.

DATA SUBJECT RIGHTS

In accordance with applicable law and depending on your location, you may be entitled to exercise some or all the following rights regarding our collection, use, and sharing of your personal information:

• Access the personal information we maintain about you;
• Update or correct any inaccurate or incomplete personal information about you;
• Request that we delete your personal information;
• Object to or restrict the processing of your personal information;
• Receive the personal information you have previously provided to UKG, in a machine-readable format, allowing you to transfer that personal information to another company at your discretion;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you; and
• File a complaint directly with your governmental representative (such as your Supervisory Authority) about how we process your personal information. 
• Dispute resolution

Exercising Your Rights

To protect your privacy and security, we take reasonable steps to verify your identity before granting access to your personal information. Please follow the instructions below based on your relationship with UKG and provide the requested information to allow us to adequately address your request. We will respond to your request within a reasonable timeframe and as otherwise required by applicable law in your location.

If you are not a California resident and would like to request access to your personal information or request erasure (right to be forgotten) of personal information previously provided, please contact [email protected].

CALIFORNIA RESIDENTS – CALIFORNIA PRIVACY NOTICE

For California residents, The California Consumer Privacy Act (“CCPA”) provides certain privacy-related rights. If you are a California resident, please click here to learn more about UKG’s privacy practices under the CCPA.

Do Not Track

Some internet browsers may be configured to send “Do Not Track” signals to the websites that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please click here.

UKG APPLICANTS & CANDIDATES

UKG applicants who want more information on how UKG processes applicant personal information, please review this section.

This section applies to the processing of Personal information by UKG collected in connection our recruitment process and with your employment application with UKG. This section applies to individuals who apply to work at UKG or provide services to UKG (including current employees who apply for new positions with us) (“you" or "Individuals").

The section describes the categories of Personal information we collect in connection with the recruitment and employee onboarding process, the purposes for which we collect that Personal information, the other parties with whom we may disclose that Personal information, and how UKG protects that Personal information. This section also provides you with information about your rights and choices with respect to your Personal information, and how you can contact us to update your Personal information or make inquiries about our privacy practices.

1. Personal information We may collect

We collect the following Personal Information about you in connection with your employment application and as part of our recruitment process, as permitted under applicable law:

Data Category	Reason for Processing*
Immigration status and work permits (if applicable)	Check regularity of your employment status
Contact information (e.g. email address, phone, address, city, state, zip code, country)	Contact
Identification details (e.g first name, last name) Gender	Identification
CV/Resume Desired salary (if applicable) Education history Results on the selection process Online identifiers and website, device and mobile app usage, and similar information collected via automated means, such as cookies and similar technologies Salary history (to the extent permitted by the local laws)	Process application
Any other information you choose to share, such as information included in your CV/resume and/or shared with us during the interview process Tax Identification number (Country Specific)	Process application and verify your suitability for current and future potential functions
Calendar availability	Scheduling
Employment history LinkedIn profile URL, the publicly available sections of your LinkedIn profile if you provided to us and other professional websites you Provided to us Results of any pre-employment testing (such as psychometric testing, credit history checks and other screening, subject to strict conditions, as permitted under applicable law) Skills inventory (including by way skills of assessments you may take part of any application process) Video/photo images or audio recordings (e.g., via virtual interviews and/or CCTV footage (where applicable))	Verify your suitability for current and future potential functions

*Lawful Basis for all of the above: The processing is necessary for performance of a contract with you, as well as legitimate interest and compliance with applicable laws and regulations.

In certain jurisdictions, and only to the extent permitted b applicable law, UKG may process Sensitive Personal information, such as racial or ethnic origin, health-related data (for example, disability information), religious beliefs, and trade union membership, for the limited purposes as set out under Section 2, below.

To the extent permitted under applicable law, UKG may receive Personal information directly from you through our Careers portal and indirectly from third parties (e.g., former employers, educational institutions, publicly available sources, and professional social networking sites such as LinkedIn, online recruitment platforms, professional recruitment agencies, and government agencies).

2. How We May Use Your Personal information

We may use your Personal information to*:

Processing Activity

Identify and contact you Consider your application Schedule and facilitate interviews Determine your suitability for current and future job roles with us Contact references or other individuals who may provide information about your employment history Perform pre-employment screening and testing Potentially prepare employment terms or an employment contract Financial planning and budgeting Engage in diversity and equal opportunity initiatives (where permitted and/or required under applicable law)

Provide reasonable workplace accommodations and safe workplace Make staffing decisions Enforce our policies and other legal rights Improve and develop our recruitment processes (including surveys) Ensure safety and security of our systems Audit, research and perform analysis of our recruiting experience on our websites Respond to inquiries, complaints or disputes Perform certain data analysis regarding use of our recruiting sites and our recruitment programs Comply with legal and other requirement

*Lawful basis for all of the above: The processing is necessary for performance of a contract with you, as well as legitimate interest and compliance with applicable laws and regulations.

Where we seek to review and implement measures to improve our recruitment activities and ensure compliance with our policies such as equal opportunity initiatives, we use aggregated data.

UKG only processes Personal information for the above purposes to the extent permitted by applicable law and, where required, only when it can rely on a legal basis. In certain cases, such as when looking to fill a job opportunity, we may process your Personal information with assistance from automated employment tools. However, all decisions with regards to the use of automated employment tools also include the use of human review and/or intervention.

3. How We Share Your Personal information

We do not sell your Personal information, share or otherwise disclose Personal information we collect about you, except as described in this Notice or otherwise disclosed to you at the time the information is collected.

We may share your Personal information we collect with:

• Companies within the UKG group, including UKG Inc.’s affiliates globally to the extent that they are involved in the recruitment and/or hiring process;
• Members of our internal departments to the extent that they are involved in the recruitment and/or hiring process. Company staff accessing Personal information are required to maintain its confidentiality and to process such information in accordance with applicable law;
• Third parties to the extent necessary for the recruitment and/or hiring process (e.g., HR hosting services, candidate relationship management services, recruitment agencies and background screening agencies). The Company enters into contractual obligations with its third-party service providers to provide appropriate protection of Personal information.

For more information on service providers, please contact us as described in the "How to Contact Us" section below.

We also may share Personal information with our service providers who perform services on our behalf and in relation to the purposes described in this Notice:

• With the consent or authorization of the Individual;
• In the context of a sale or transfer involving all or a portion of the Company’s business or assets (including in the event of a reorganization, dissolution or liquidation);
• In response to requests by government agencies, such as law enforcement agencies;
• To protect the rights and properties of the Company;
• If required to do so by law, regulation, or legal process (such as a court order or subpoena);
• When we believe disclosure is necessary or appropriate to prevent physical harm to UKG employees or financial loss;
• As part of an investigation of suspected illegal activity.

The Company enters into contractual obligations with its third-party service providers to provide appropriate protection of Personal information.

Choosing Not to Share Your Personal information

Denial of Requests

UKG may deny a request submitted in accordance with the above as permitted by applicable law in your location. UKG will endeavor to notify you regarding any decision and reason(s) for denial in a timely manner and otherwise in accordance with applicable law in your location.

Dispute Resolution

In accordance with this Website Notice, UKG will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of your personal information. Additionally, UKG will cooperate with governmental authorities upon request.

Any privacy-related dispute or concern that is still unable to be resolved to your satisfaction shall be handled in accordance with applicable dispute resolution procedures, free of charge, through our U.S.-based third-party dispute resolution provider TRUSTe.

We strongly encourage you to contact us directly with any complaints you may have with regard to this Website Notice or our privacy practices prior to proceeding to the arbitration procedure described above.

SECURITY

UKG utilizes physical, technical, and administrative controls and procedures designed to safeguard the information we collect, prevent unauthorized access or disclosure, to maintain data accuracy of your personal information, and to restrict the processing of your personal information as set forth in this Website Notice.

We utilize a variety of physical and logical access controls, firewalls, intrusion detection and prevention systems, network and database monitoring, anti-virus, and backup systems. We use encrypted sessions when collecting or transferring sensitive data through our Site.

We limit access to your personal information and data to those persons who have a specific business purpose for maintaining and processing such information. Our employees who have been granted access to your personal information are made aware of their responsibilities to protect the confidentiality, integrity, and availability of that information and have been provided training and instruction on how to do so.

For additional information regarding UKG’s commitment to cybersecurity, please refer to UKG’s ESG – Cybersecurity page.

ENFORCEMENT AND VERIFICATION

UKG will periodically assess its operations to validate compliance with this Website Notice.

We will take reasonable steps to prevent or address any unauthorized use or disclosure of your personal information in a manner contrary to this Website Notice. We hold our employees and third parties accountable for maintaining the trust that you place in UKG.

CHANGES TO THIS PRIVACY NOTICE

This Website Notice is effective August 7, 2023. UKG reserves the right to modify or amend this Website Notice at any time consistent with applicable laws. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT INFORMATION

At any time, you may contact UKG with questions or concerns about this Website Notice at [email protected].

Written responses may also be submitted to:

UKG Inc. 
Attention: VP Deputy General Counsel 
900 Chelmsford St.& 
Lowell, MA 01851

Those located in the EU may contact our European representatives via email at [email protected]. UKG Inc. EU representative is:

PeopleDoc SAS 
Attention: Data Privacy Officer 
53 rue d’Hauteville 
75010 Paris, France

UKG will respond to all correspondence within a reasonable timeframe, including as required by applicable law.