CCPA Notice- Employees

Last updated: June 1, 2023

This Privacy Disclosure (“Disclosure”) describes how Glidepath Holdings, Inc.’s subsidiary MassMutual Ascend Life Insurance Company (“MassMutual Ascend”) processes Personal Information about job applicants as well as current and former employees (collectively, “Personnel”) in connection with employment-related functions. This Disclosure does not apply to Personal Information collected about other types of individuals or Personal Information collected from you in different contexts. For example, if you interact with our commercial websites or job applicant websites, the MassMutual Ascend California Consumer Privacy Disclosure and/or privacy disclosure posted on that website will apply rather than this Privacy Disclosure.

Changes: We may update this Disclosure from time to time. Any updated Disclosure will be effective when posted. Please check this Disclosure periodically for updates. If required by law, we will contact you directly to provide you with an updated Disclosure.

1. Sources of Personal Information

We collect Personal Information about you from the following sources:

A. Directly from you. We may collect Personal Information you provide to us directly, such as when you apply for employment with us, when you register for benefits, sign up for events, provide feedback, and through other interactions with us prior to, during, or after your employment with us.

B. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through tracking technologies. This may include information about how you browse the internet using Company devices and systems and send and receive emails.

C. From third parties. We may receive Personal Information from entities that operate independently of us, such as recruitment services. Where permitted or otherwise authorized by law, information received from third parties may include the results of background checks.

D. From service providers. We may receive Personal Information from entities retained to provide a service who collect information on our behalf with respect to such service.

E. From other Personnel and our affiliates and subsidiaries. For example, we may receive Personal Information from your colleagues or supervisors in the context of performance evaluations.

F. From MassMutual Ascend financial professionals (such as agents and brokers).

G. From publicly available sources. We may collect Personal Information about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Disclosure, including third party sources, and use or disclose it for the purposes identified below.

2. Types of Personal Information We Collect

We may collect the following types of Personal Information:

A. Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers.

B. Records about you, such as financial information (including financial account number used for payroll), signatures, background check information (where permitted or required by law), and your physical characteristics or a description of you.

C. Protected class and demographic information, such as age (including birthdates) and gender.

D. Commercial information, such as records of business transactions, salary and wage information, and payroll and benefits data.

E. Internet or other electronic network activity information, such as information relating to your use of or interactions with MassMutual Ascend networks, systems, devices, email, applications, and platforms, including your browsing history, search history, and other interactions.

F. Non-precise geolocation data, such as your location as derived from your IP address.

G. Audio, visual, or other sensory information, such as photographs, security camera footage in the public areas of MassMutual Ascend’s facilities, and recordings of calls and video conferences.

H. Professional or employment-related information, such as job title, organization, professional licenses, credentials, specialty, professional affiliations, professional experience, references, performance and other evaluation information, disciplinary information, resumes, interview notes, human resource records, payroll, board of directors’ appointments, or other professional information.

I. Education information.

J. Inferences drawn from any of the information we collect about your preferences and behavior.

K. Sensitive Personal Information, such as Social Security number, driver’s license number, or passport number; account log-in information; racial or ethnic origin, if you voluntarily provide it; content of mail, email, and text messages where we are not the intended recipient (such as messages that we monitor for compliance and security purposes); information about your health; medical or health insurance information, including insurance policy number; and information relating to sexual orientation, if you voluntarily provide it.

3. How We Use Personal Information

We may use Personal Information for the following purposes:

A. In connection with an employment application, such as assessing your application, interview, and test results for suitability for the position for which you have applied or other open positions; communicating with you concerning job openings or your application; conducting pre-employment verification and screening; offering you the job position, in our discretion; notifying you of job opportunities (including from affiliates in our group, where we have shared your job application with them); and dealing with any inquiry, challenge, or request for feedback received in relation to our recruitment and hiring decisions.

B. Human resources management, such as administering payroll and benefits (including leave of absence benefits and use, pensions, government-related programs); logistics; planning and managing corporate travel and other reimbursable expenses; development and training; absence monitoring; timekeeping; performance appraisals; disciplinary and grievance processes; administration of termination of employment; career planning; administration of relocation; assessing qualifications and eligibility for a particular role or project; diversity and inclusion surveys and other activities (including to understand make up and representation in the workforce, for pay gap initiatives, and to allow us to offer support to certain demographic groups); background checks and reference checks; and complaint/hotline programs.

C. For our internal business purposes, such as managing and improving our recruitment and employment functions; enforcing our policies and rules; management reporting; managing MassMutual Ascend assets including: office locations and emergency planning; project management; auditing; maintaining records on employment business activities (such as accounting and commercial activities); document management and similar activities; budgeting; IT administration of our technologies, network, and intranet; IT security management and tasks; analyzing and managing meeting information (including, but not limited to, recording content, conversations and discussions, which may include your voice and/or images in case of video conferences, trainings, meetings, and other events); documenting corporate decision-making processes; making online events available to our Personnel for training purposes and/or to allow them or our partners to review such events after they have finished; helping Personnel improve meeting management; increasing meeting productivity; optimizing meeting resource distribution; and providing insights into interactions with people you network with.

D. For our internal research and business improvement purposes.

E. For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against the Company, its personnel, and its customers; for the establishment, exercise or defense of legal claims; protecting the Company, your, our customers’, and other third parties’ safety (including managing spread of communicable diseases), property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.

F. In connection with a corporate transaction, such as if we acquire, some or all of our assets are acquired by another entity.

G. For marketing or promotional purposes, including externally promoting MassMutual Ascend and our business. We may do so via social media, through public relations materials and communications, reputation and business-development efforts, branding, at events, and directly to business customers. For example, we may publicly disclose the names and work contact information of sales representatives or post pictures of Personnel who attend MassMutual Ascend events.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

CCPA Notice Employees

	Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
Identifiers (Section 2.A)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Records about you (Section 2.B)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Protected class and demographic information (Section 2.C)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Commercial Information (Section 2.D)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Internet or other electronic network activity (Section 2.E)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Geolocation data (Section 2.F)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Audio, visual, or other sensory information (Section 2.G)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Professional or employment-related information (Section 2.H)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Educational Information (Section 2.I)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Inferences (2.J)	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure
Sensitive Personal Information (Section 2.K)	Sensitive Personal Information (Section 2.K) • Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure The categories of recipients in the chart above are used to

Our options at a glance

	Identifiers (Section 2.A)	Records about you (Section 2.B)	Protected class and demographic information (Section 2.C)	Commercial Information (Section 2.D)	Internet or other electronic network activity (Section 2.E)	Geolocation data (Section 2.F)	Audio, visual, or other sensory information (Section 2.G)	Professional or employment-related information (Section 2.H)	Educational Information (Section 2.I)	Inferences (2.J)	Sensitive Personal Information (Section 2.K)
Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	• Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure	Sensitive Personal Information (Section 2.K) • Affiliates and subsidiaries • Benefits services providers • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government agencies, and other recipients for legal, security, and safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure The categories of recipients in the chart above are used to

The categories of recipients in the chart above are used to mean:

A. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.

B. Benefits services providers, such as companies that provide health, wellness and insurance and other financial and voluntary benefits.

C. Professional consultants, such as HR operations consultants, accountants, benefit consultants, IT consultants, staffing consultants, career development, training and outplacement consultants, testing companies, lawyers, accountants and financial advisors.

D. Vendors necessary to complete transactions you request, such as shipping companies.

E. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements; to enforce or apply our agreements and policies; and to protect Company, our customers’, or third parties' safety, property, or rights.

F. Other entities in connection with a corporate transaction, such as if we acquire assets, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.

G. Entities to which you have consented to the disclosure.

5. Data Retention

Our Information Governance and Records Management Program establishes and maintains company policies and procedures governing the creation, retention, storage, and disposition of corporate records and information, provided that such information to be deleted or destroyed is not subject to regulatory requirement to retain it or a legal hold. We retain corporate records for the minimum time period required by law or regulation and/or for a longer period of time consistent with business needs. We determine retention periods for corporate record information using both legal/regulatory citations and business requirements. Citations for retention periods are regularly reviewed by outside counsel and updated as necessary. CCPA rights request records are subject to a two-year retention period as required by California law.

6. Data Subject Rights

California Consumers may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:

Right to Know. You may request information about the categories of Personal Information we have collected about you; the categories of sources from which we collected the Personal Information; the purposes for collecting, selling, or sharing the Personal Information; and to whom we have disclosed your Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you.
Right to Delete. You may request that we delete Personal Information that we have collected from you.
Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.
Right to Limit Sensitive Personal Information Processing. We generally only use Sensitive Personal Information that is subject to the CCPA for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you. In limited circumstances, you may have the right to limit our processing of your Sensitive Personal Information. In limited circumstances, you may have the right to limit our processing of your Sensitive Personal Information.
Right to Opt Out of Sale/Sharing. You may request to opt our from the sale or sharing of your Personal Information. We do not knowingly sell or share personal information in a manner that would be considered a sale of any Personal Information of minors under the age of 16.

You may exercise a Right to Know, Right to Delete, Right to Correct, and Right to Limit Sensitive Personal Information Processing via our webform at https://www.massmutualascend.com/privacy-policy or call us at 1-888-595-6918.

You may exercise your preferences and learn about the Right to Opt-Out of Sale/Sharing by visiting https://www.massmutualascend.com/privacy-requests. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights.

Verification: In order to process requests, we may need to obtain information to locate you in our records or verify your identity using reasonable methods. For Right to Know, Right to Delete, Right to Correct, and Right to Limit Processing of Sensitive Personal Information, we will collect some or all of the following data elements: Name, Date of Birth, and part of your Social Security Number, email address, phone number, and home address. In some cases we may ask for more or different information if needed to verify you. We may also use a a third-party identity verification and fraud prevention service which may present you with additional knowledge-based questions. When it comes to identity verification, our third party only tells us whether your identity was verified, and we do not use this information for any other purpose.

Authorized Agents: Authorized agents may exercise rights on behalf of prospective, current, and former workforce by submitting a request via our online webform located at https://www.massmutualascend.com/privacy-policy and indicating that they are submitting the request as an agent. Agents should provide their own information to verify the agent’s identity, after which we will contact the agent with additional instructions to complete the submission process on behalf of prospective, current, and former workforce. We may require agents to demonstrate authority to act on behalf of prospective, current, and former workforce by providing signed permission and may require prospective, current, and former workforce to directly verify their identity with us using the methods described above.

Timing: We will respond to Right to Know, Right to Delete, and Right to Correct requests within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request.

7. Contact Information

If you need assistance submitting a request or have questions regarding this Disclosure or how the Company uses your Personal Information, please contact us at 1-888-595-6918 or email us at [email protected].