California Applicants CCPA Notice at Collection

Department	Legal
Subject	Privacy
Department Head	Stefanie Box, Chief Legal Officer
Last Update	October 31, 2025
Functional Specialist	Katherine Deforest, Associate General Counsel, Labor & Employment
Data Classification	Public ☑️ Internal Restricted Personal Information
report an ethics violation or concern using the Thrive Reporting system at http://Tinyurl.com/ThriveReporting or through the following QR code

This California Applicant Privacy Notice ("Notice") is provided pursuant to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), to inform job applicants residing in California (“you”) about our personal information (PI) collection and use practices.

1. Categories of Personal Information We Collect and Use

Pathway Vet Alliance, LLC d/b/a Thrive Pet Healthcare (“Thrive” or “we”) collects and uses Personal Information for human resources, employment, benefits administration, health and safety, and business-related purposes, and to be in legal compliance. Below are the categories of Personal Information we collect and the purposes for which we intend to use this information:

We also collect Sensitive Personal Information, such as your Social Security number, driver's license number, and potentially health information (if job-related and necessary), for purposes of background checks, legal compliance, and making reasonable accommodations. 

We may also use your Personal Information to:

• Perform workforce analytics, data analytics, and benchmarking;

• Investigate and enforce compliance with, and potential breaches of, Thrive policies and procedures;

• Engage in corporate transactions requiring review of employees' records, such as for evaluating potential mergers and acquisitions of Thrive;

• Administer and maintain Thrive’s operations, including for safety purposes;

• Exercise or defend the legal rights of Thrive and its employees, affiliates, customers, contractors, and agents; and

• Recruit and evaluate job applicants and candidates for employment.

2. Automated Decision-Making Technology (ADMT) 

We may use Automated Decision-Making Technology (ADMT), which uses computation to substantially replace human decision-making, to make a significant decision about you related to your employment, such as initial applicant screening or skills assessments. 

• Your Rights Regarding ADMT: You have the right to opt out of the business's use of ADMT for significant decisions and the right to access information about how the ADMT works.

• How to Exercise: If you wish to opt out of our use of ADMT or request access to information about our ADMT use, contact us using the methods provided in the "Contact Us" section below. 

3. Data Retention Period

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for legal, accounting, or reporting requirements. Generally, we will retain applicant information for seven years after the application process is complete, unless a longer period is required by law. 

4. Your CCPA Rights

As a California applicant, you have the right to:

• Know about the personal information we collect and how it is used.

• Request that we delete your personal information, subject to certain exceptions.

• Request that we correct inaccurate personal information we maintain about you.

• Opt-out of the sale or sharing of your personal information (note: we do not sell or share applicant PI).

• Not be discriminated against for exercising your CCPA rights.

• Access information we have collected about you since January 1, 2022

5. Contact

If you have questions, would like to exercise your rights, or need this Notice in an alternative format due to a disability, please contact peopleoperations@thrivepet.com or visit our https://www.thrivepetcare.com/privacy. 

6. Administration of This Policy

The Legal Department is responsible for administering this Policy. All Thrive Team Members are responsible for consulting and complying with the most current version of this Policy. If you have any questions regarding this Policy that are not addressed in this Policy, please contact the Legal Department.

Amendment and Revision History

We are committed to continuously reviewing and updating our policies and procedures. The Company, therefore, reserves the right to amend, alter, or terminate this policy/procedure at any time and for any reason, subject to applicable law. When material changes are made, Thrive will post the changes on our internal website and provide Team Members with subsequent notice consistent with local laws or regulations.