CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE

Notice for California Consumers

Effective Date: April 15, 2026

This Notice for California Consumers (“Notice”) supplements the information contained in twrk’s Privacy Policy and applies solely to residents of California. It is provided in accordance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”).

This Notice explains:

  1. Your rights under the CCPA

  2. The categories of personal information we collect and sources

  3. How we use, disclose, and share personal information

  4. Your choices and how to exercise your rights

For additional details, please refer to our Privacy Policy.

1. SALE OR SHARING OF PERSONAL INFORMATION

1.1 No Sale of Personal Information

twrk does not sell your personal information.

1.2 Sharing of Personal Information

We may engage in “sharing” as defined under the CCPA (i.e., disclosure for cross-context behavioral advertising).

We may share personal information with:

  • Advertising and marketing partners

  • Analytics providers

  • Service providers acting on our behalf

1.3 Right to Opt Out of Sharing

You have the right to opt out of the sharing of your personal information.

You may exercise this right by:

  • Contacting us at: legal@twrk.com

  • Adjusting your account settings (where available)

  • Using a Global Privacy Control (GPC) signal, which we honor where required by law

2. YOUR RIGHTS UNDER THE CCPA

Subject to verification and applicable exceptions, California residents have the following rights:

2.1 Right to Know / Access

You may request that we disclose:

  • Categories of personal information collected

  • Sources of that information

  • Business or commercial purposes for collection

  • Categories of third parties with whom we share or disclose information

  • Specific pieces of personal information we have collected about you

2.2 Right to Delete

You may request deletion of your personal information, subject to legal exceptions, including where retention is necessary to:

  • Complete transactions

  • Detect or prevent security incidents

  • Comply with legal obligations

  • Exercise or defend legal claims

2.3 Right to Correct

You may request correction of inaccurate personal information.

2.4 Right to Opt Out of Sharing

You may direct us not to share your personal information for cross-context behavioral advertising purposes.

2.5 Right to Limit Use of Sensitive Personal Information

We use sensitive personal information only as permitted by law. Therefore, a separate limitation mechanism is not required.

2.6 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights, including by:

  • Denying services

  • Charging different prices

  • Providing a different level or quality of service

2.7 Right to Notification

We will notify you before collecting additional categories of personal information or using your data for materially different purposes.

3. SUBMITTING REQUESTS

To exercise your rights, you (or your authorized agent) may contact us at: legal@twrk.com

We will:

  • Verify your identity as required by law

  • Respond within applicable timeframes (generally 45 days)

4. CCPA / CPRA DISCLOSURES AND INQUIRIES

If you have questions about your rights under the CCPA or CPRA, or would like to submit a request, please contact us at legal@twrk.com.

We will respond to verifiable consumer requests in accordance with applicable law.

twrk currently does not meet the statutory thresholds requiring public reporting of annual CCPA metrics. However, we may provide additional information upon request where required.

5. MINORS AND PERSONAL INFORMATION

5.1 Platform Age Restrictions

The Platform is not intended for individuals under the age of 18, and we do not knowingly collect personal information from individuals under 18.

5.2 CCPA Compliance (Under Age 16)

In accordance with the CCPA:

  • We do not sell or share personal information of consumers under age 16 without required opt-in consent

  • We do not have actual knowledge of selling or sharing personal information of consumers under 16

5.3 Protective Position (Under Age 18)

twrk does not:

  • knowingly provide services to individuals under 18

  • knowingly sell or share personal information of individuals under 18

5.4 Remediation

If we become aware that personal information has been collected from a minor without appropriate consent, we will take steps to delete such information.

6. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information:

6.1 Identifiers

Examples: name, email, IP address, account name
Sources: user input, platform activity, partners, service providers

6.2 Protected Classifications

Examples: gender, age (if provided)
Sources: user input, inferred data

6.3 Commercial Information

Examples: purchases, subscriptions
Sources: user activity, transactions

6.4 Internet / Network Activity

Examples: browsing behavior, interactions, feature usage
Includes: automated application activity performed on your behalf
Sources: platform usage, integrations

6.5 Geolocation Data

Sources: device and usage data

6.6 Professional / Employment Information

Examples: resume, work history, skills
Sources: user input, third parties, employers

6.7 Inferences

Examples: job preferences, match scores
Sources: platform analytics and AI systems

6.8 Sensitive Personal Information

May include:

  • Account security data

  • Communications

  • Optional demographic data

We use sensitive personal information only for permitted purposes.

7. DATA RETENTION

We retain personal information:

  • As long as your account is active

  • As necessary to provide services

  • As required by law or for legitimate business purposes

8. CATEGORIES OF PERSONAL INFORMATION WE SHARE

We may share the following categories:

  • Identifiers

  • Internet activity

  • Commercial information

  • Inferences

We do not share sensitive personal information for cross-context behavioral advertising.

9. CATEGORIES OF PERSONAL INFORMATION DISCLOSED FOR BUSINESS PURPOSES

We may disclose personal information for the following purposes:

9.1 Auditing

Verifying interactions and performance

9.2 Security and Integrity

Fraud prevention, enforcement, and legal compliance

9.3 Service Improvement

Debugging, analytics, and product development

9.4 Service Providers

Vendors performing services on our behalf under contract

9.5 Communications and Marketing

Providing communications and permitted marketing services

10. CHANGES TO THIS NOTICE

We may update this Notice at any time. Changes will be reflected by updating the “Effective Date.”

Your continued use of the Platform constitutes acceptance of any updates.