Last updated: November 1, 2023 CCPA Privacy Notice

Applies to residents of the State of California that are TGS owners, directors, officers, employees, contractors and/or job applicants.

TGS Management Company, LLC (“TGS,” “we,” “us,” or “our”), collects, discloses, and otherwise processes personal information relating to its employees, contractors and job applicants for human resources, employment, benefits administration, health and safety, and other business-related purposes, and to comply with applicable laws and regulations. This CCPA Privacy Notice (the “Notice”) explains these practices to our owners, directors, officers, employees, contractors and job applicants that reside in the State of California and provides guidance on exercising their rights under the California Consumer Privacy Act (“CCPA”). If you are an employee, contractor, or job applicant at TGS but you do not reside in the State of California, this Notice does not apply to you.

I. The Personal Information We Collect, Why We Collect it, and How Long We Keep it

a) What kind of personal information TGS collects

We may collect the categories of personal information (including sensitive information) listed in the tables below for the specific business purposes listed next to them.

Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect information that falls within the sensitive personal information categories under the CCPA, we do not process it for the purpose of inferring characteristics about you and, therefore, you do not have the right to limit how we use and disclose such information.

The table below outlines the categories of Personal Information we collect (with examples) and the Business Purpose for its collection.

Personal Information Category	Business Purpose
Identifiers, such as your full name, gender, date of birth, signature, home address, telephone numbers, email addresses, and emergency contact information, as well as similar information for your dependents and beneficiaries	Conduct employee/contractor onboarding Maintain and administer timekeeping, payroll, expense reports, employee/contractor training and development, and employee benefit plans, including enrollment and claims handling Maintain personnel records (including job performance, goals and performance reviews, promotions, discipline, termination, and provision of references), and comply with record retention requirements Provide employees/contractors with human resources management services, data maintenance and support services, and, as applicable, the creation, maintenance, and security of your online employee accounts Communicate with employees/contractors and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws Manage and monitor employee/contractor access to or use of TGS facilities, properties, equipment, systems (including information systems), electronic devices, network, and data Produce internal and external communications (such as newsletters, magazines and website articles) to promote and celebrate the achievements of the company, and its past and present employees Ensure productivity and adherence to TGS policies Conduct internal audits and investigate complaints, grievances, and suspected violations of TGS policies Engage in corporate transactions requiring review of employee/contractor records, such as for evaluating potential mergers and acquisitions involving TGS Maintain commercial insurance policies and coverage, such as for workers compensation and other liability insurance Perform workforce analytics, data analytics and benchmarking Administer and maintain TGS operations, including for safety purposes Comply with applicable laws and regulations Respond to law enforcement requests and as required by applicable law or court order
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone numbers, passport number, driver’s license or state identification card number, immigration status, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information	Same business purposes as for Identifiers (see above)
Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information)	Comply with federal and state equal employment opportunity laws Design, implement, and promote TGS’s diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits, grievances, and suspected violations of TGS policies Exercise or defend the legal rights of TGS, its employees, customers, contractors, and agents
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members	Design and administer employee benefit plans and programs, including for leaves of absence Maintain personnel records and comply with record retention requirements Communicate with employees/contractors and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of TGS’s property, including its information systems, electronic devices, network, and data Ensure productivity and adherence to TGS policies Conduct internal audits and investigate complaints, grievances, and suspected violations of TGS policies Evaluate and provide feedback about job performance, facilitate better working relationships, and for employee professional development Exercise or defend the legal rights of TGS, its employees, customers, and agents
Non-public educational information, such as academic and professional qualifications, educational records, references, degrees and vocational certifications obtained, report cards, and transcripts	Evaluate an individual’s appropriateness for promotion or transfer to a new position at TGS
Complete account access credentials, such as usernames or account details, combined with required access/security code or password	Provide employees/contractors with human resources management services and data maintenance and support services Prevent unauthorized access to or use of TGS’s property, including its information systems, electronic devices, network, and data Ensure productivity and adherence to TGS policies Conduct internal audits and investigate complaints, grievances, and suspected violations of TGS policies
Racial or Ethnic Origin	Comply with federal and state equal employment opportunity laws Design, implement, and promote TGS’s diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits and investigate complaints, grievances, and suspected violations of TGS policies
Personal information collected and analyzed concerning your health, including health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information	Investigate and process workers’ compensation claims Process health insurance claims Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries

b) Data retention periods for personal information

TGS determines the retention periods of each category of personal information based on the following criteria:

The purposes for which TGS processes the personal information (TGS needs to retain the personal information as long as necessary for such purposes); and
Tax, legal and regulatory obligations and requirements (laws or regulation may set, or recommend, a minimum period for retention of your personal information).

If you have any questions regarding the data retention policies and practices applicable to your personal information, please reach out to the TGS CCO via means outlined in section 5 of this Notice.

c) “Selling” or “sharing” of employment and work-related data

TGS will not sell or share (as defined in the CCPA) the personal information we collect in connection with your employment, job application, or work you perform for us.

2. How We Obtain Your Personal Information

We receive your personal information mostly directly from you, for example during your job application process, your employee/contractor onboarding process, and during the selection of your benefits as an employee.

In addition to this, we may receive personal information about you from the following categories of sources:

Publicly available sources;
Your references;
Companies that conduct background checks, screen for know your customer (KYC), anti-money laundering (AML), and/or other factors;
Current and former employers, colleagues, customers, clients, or other professional contacts; and
Security cameras, time clocks, phone logs, GPS systems on company vehicles, and similar technology.

3. What Kind of Personal Information We Disclose to Others

We may disclose the following categories of personal information to the following categories of service providers and/or contractors for a business purpose. We do not disclose your personal information to others who are not our service providers or contractors except as explicitly mentioned in this Notice.

Personal Information Category	Business Purpose
Identifiers California Customer Records employment and personal information Protected classification characteristics under California or federal law Commercial information Professional or employment-related information Personal information collected and analyzed concerning your health Non-public education information Information related to immigration status Complete account access credentials Financial information	Companies that conduct background checks, screen for KYC, AML, and/or other factors Payroll Providers Law firms, accountants, and other providers of professional services
Identifiers California Customer Records employment and personal information Protected classification characteristics under California or federal law Personal information collected and analyzed concerning your health Professional or employment-related information Information of dependents or other individuals	Insurance companies
Identifiers Protected classification characteristics under California or federal law Commercial information Professional or employment-related information Information of dependents or other individuals	Retirement plans Loan providers
All categories of personal information mentioned above	Service Providers that provide internal auditing services, workforce analytics, data analytics and/or benchmarking services Data storage companies, including cloud providers

We may also disclose any category of personal information for one or more of these additional business purposes:

Complying with applicable laws, judicial or administrative orders, and responding to law enforcement requests;
Evaluating or closure of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where personal information is transferred; and
Exercising of our legal rights and protection of our interests in connection with any claim, action or proceeding brought by or against us.

4. Your Privacy Rights

You have the following rights regarding your personal information:

Right to Know: You have the right to know:
- The categories of specific personal information we collect, use, disclose, sell, and/or share and have collected, used, disclosed, sold, and/or shared in the past; and
- The specific pieces of personal information we have collected from or about you.
Right to Delete: You have the right to request deletion of your personal information. We will honor such request but might not be able to fulfill your request if we (or our service providers or contractors) are required to retain your personal information.
Right to Correct: You have the right to request that we correct inaccurate personal information about you. We will honor such request but might not be able to fulfill your request if it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive.
Right to Opt-Out of the Sale or Sharing of Personal Information: You have the right to opt-out of the “sale” or “sharing” of your personal information. Please note, however, that we do not “sell” or “share” the personal information of our employees, job applicants or contractors as those terms are defined under the CCPA.
Anti-Retaliation Right: We are prohibited from discriminating against you for exercising any of the above rights.
Right to Designate an Authorized Agent: If you submit a request to know or delete your personal information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us.

5. Exercising Your Privacy Rights

To exercise the rights described above, please submit a request to us by using the methods outlined below.

By filling out the webform accessible at the bottom of this page;
Calling us at our toll-free number 866-837-3199; or
Reaching out to the address below and requesting a form to submit your request.

ATTN: CCPA COMPLIANCE

TGS Management Company, LLC

33 Witherspoon St, Fl 3

Princeton, NJ 08542-3212

In order to fulfill your request, we may need you to (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (such as your name, email, and/or employee ID), or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it (e.g., an explanation of which right you would like to exercise, and relevant details about your request such as the personal information you want deleted or corrected). We may need you to procide us with additional information if we cannot initially verify your identity or request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you.

We will confirm receipt of your request within then (10) business days of its receipt, and endeavor to respond within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We may charge a reasonable fee to process or respond to your requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

6. Updates

This Notice is effective as of the date of the “Last Update” stated at the top of this Notice, which is posted on our public website and the Confluence portal. We may change this Notice from time to time to reflect changes in our business, legal or regulatory obligations, so please check this Notice on a regular basis. TGS will not collect additional categories of your personal information or use the personal information already collected for additional purposes without providing you with notice of our intent to do so. Any changes to this Notice will become effective on the date they are communicated to you by posting the updated Notice to our public website and the Confluence portal. By engaging or interacting with us after we make any changes to this Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your personal information is governed by the Notice in current effect.

7. How to Contact Us About this Notice

If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact the TGS CCO by means outlined in section 5 of this Notice.

Questions?

Please click the button below to contact us with questions regarding the privacy policy.