Last updated: September 2026

Boulevard Employee & Personnel Privacy Notice

Summary

Boulevard Labs, Inc., and its operating groups, subsidiaries and affiliates, (the “Company” or “we”) are committed to protecting the privacy and security of personal information of our current and former employees (including temporary employees), job applicants, officers and directors (collectively, “Employees”) and contractors, agents, contingent, and other personnel (together with Employees, “Personnel”). The Company collects personal information of Personnel and their emergency contacts and beneficiaries in connection with its human resources activities.

Scope

Unless otherwise stated, this Boulevard Employee & Personnel Privacy Notice (“Notice”) applies to Boulevard Personnel globally.

Sources of Personnel Personal Data

We collect personal data from a variety of sources, including:

• You, and your emergency contacts and beneficiaries
• Our recruitment service providers
• Applicable law enforcement and governmental agencies
• Your former employers and the references you provide
• Boulevard human resources, management, and IT personnel and equipment
• Our service providers
• Healthcare providers and insurance companies
• Publicly available sites and sources

How We Use Personnel Personal Data

We collect personal data for a variety of business purposes, including:

• Recruiting and assessing suitability, aptitude, skills, qualifications, and interests for employment with Boulevard
• Communicating with candidates about the application process
• To assist our Personnel in obtaining an immigration visa or work permit (where required or requested)
• Workflow management, including assigning, managing and administering projects and booking travel arrangements
• Human Resources operations, including performance management
• Compensation, payroll, the provision and administration of benefits, and stock plan administration
• To pursue our legitimate interests (e.g., fraud prevention, network and information security, disclosure to affiliated organizations for administrative tasks, monitoring overtime, Personnel monitoring for safety or management, improving the safety of our workplace, whistleblowing schemes, enforcement of legal claims, and research purposes)
• Helpdesk and IT support services
• Internal and/or external or governmental compliance investigations
• Internal or external audits
• Where necessary for the establishment or exercise of legal claims or defenses
• To improve our workplace and Personnel satisfaction
• Diversity and inclusion initiatives
• Emergency contacts and services
• Personnel safety
• Facilities management
• To comply with our legal obligations
• Acquisitions, divestitures, and integrations
• As you otherwise agree or consent

How We Disclose Personnel Personal Data

• Vendors and Service Providers. We may share personal data we receive with vendors and service providers, such as for Human Resources operations and the provision of IT and related services.
• Disclosures to Protect Us or Others or Comply with the Law. We may access, preserve, and disclose your personal data if we believe doing so is required or appropriate to:
  • Comply with legal requirements, including required pay equality reporting
  • Comply with law enforcement requests and legal processes such as court orders or subpoenas
  • Protect your, our, or others’ rights, property, or safety
  • Enforce our policies or contracts
  • Collect amounts owed to us
  • Assist with an investigation or prosecution of suspected or actual illegal activity
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, your personal data may be transferred as part of such a transaction as permitted by law and/or contract.

With Your Permission. We may process your Personal Data in other ways with your express consent.

We do not sell or share Personnel personal data for valuable consideration or cross-contextual advertising.

The Company also collects legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to legal claims. The Company collects this information to comply with legal and contractual requirements and to establish, exercise, and defend legal and contractual rights and claims.

Beneficiary and Emergency Contact Information

We collect the following personal information to contact in the event of an emergency:

• Name and contact information
• Relationship to Employee

We collect the following personal information to enroll and administer benefits such as for dependents and beneficiaries:

• Name and contact information
• Relationship to the Employee
• Birth date
• Social Security Number
• Information necessary to process benefits claims

Your Choices and Rights

Depending on applicable law, you may have the right to:

• Request access to or a copy of your personal data, including in a portable format
• Request that we delete your data from our systems
• Object to or restrict processing of your data
• Correct inaccurate or outdated personal data in our systems
• Limit the use of sensitive personal data

For more information or to exercise these rights, please contact us as described below.

Data Retention

We generally retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, financial, or reporting obligations, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal data, we may consider factors such as:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure of your personal data
• The purposes for which we process your personal data
• Whether we can achieve those purposes through other means
• Applicable legal requirements, including mandatory retention periods, statutes of limitation, legal holds, and litigation requirements

When we no longer require the personal data we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Note that in some cases, even if you submit a data deletion request, we may be required to retain your personal data, such as to comply with the law; maintain records of transactions; exercise, establish, or defend legal claims; or protect against fraud or abuse of our systems.

Security

We take steps to ensure that your personal data is treated securely and in accordance with this Notice. Unfortunately, we cannot ensure or warrant the security of any data you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Contact Us

If you have any questions or concerns regarding this Notice or the collection of your personal information, please contact: [email protected].