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CALIFORNIA PRIVACY POLICY

Last Updated: January 2021

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ManpowerGroup Inc. (“Company,” “we,” “our,” or “us”) takes your privacy seriously. We want you to know how we collect, use, share, and protect your Personal Information and about the rights of California Consumers under California law.

This Privacy Policy addresses the following topics (click on one of the links below to jump to the listed topic):

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at accessibility@manpowergroup.com for assistance.

The Scope Of This Privacy Policy

What Is Personal Information?
“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

Whose Personal Information Is Covered By This Policy?
This California Privacy Policy applies to the Personal Information of residents of the State of California in their capacity as consumers (“California Consumers”).

What Personal Information Does This Privacy Policy Cover?
This Privacy Policy applies to all Personal Information of California Consumers that we collect both online and offline, including through California Consumers’ (a) visits to our websites, and (b) use of our applications or services that reference this Privacy Policy (collectively, the “Services”).

Whose Personal Information Is Not Covered By This Privacy Policy?
For purposes of this Privacy Policy, “Consumer” does not include:

  • California residents who are Company’s employees, job applicants, directors, officers, or contract workers (collectively, “HR Individuals”), or the emergency contacts of HR Individuals or the dependents or spouses who receive Company benefits by virtue of their relationship to an HR Individual in their capacities as HR Individuals or emergency contacts, dependents, or spouses; or
  • California residents who are employees or other agents of a business engaged in a transaction with Company in their capacities as employees or agents of that business.

What Else Should I Know About The Company’s Handling Of California Consumers’ Personal Information?
Please read Company’s Terms of Use and our General Privacy Statement available at https://www.manpowergroup.com/privacy-policy carefully, as they contain important information about your use of the Services. If you have any questions, please contact us using the information below.

The Company’s Collection, Use And Disclosure Of Personal Information

Categories Of Personal Information Collected
In the last 12 months, Company collected the following categories of Personal Information about California Consumers:

  • Identifiers, including: full name; address; email address; telephone number; IP address; and account username.
  • Non-Public Education Information, including: education level and CV/resume information.
  • Characteristics of Protected Classifications Under California or Federal Law, including: gender and age.
  • Professional or Employment-Related Information including: CV/resume information and employer information.
  • Commercial Information, including: Services obtained or considered.
  • Sensory Information, including: video surveillance of branch locations.
  • Internet Or Other Electronic Network Activity Information, including: pages visited on Company’s websites and links clicked; IP address; location information; browser and device data; and language preferences.
  • Profile Information, including: results of self-assessment questionnaires and inferences drawn from the categories of Personal Information listed above to create a profile reflecting a California Consumer’s preferences.

Purposes For Using Personal Information Collected
In the last 12 months, Company used the categories of Personal Information listed above for the following purposes:

Categories of Personal Information Purpose For Which Information Is Use
  • Identifiers
  • Non-Public Education Information
  • Characteristics of Protected Classifications Under California or Federal Law
  • Professional or Employment-Related Information
  • Commercial Information
  • Sensory Information
  • Internet or Other Electronic Network Activity Information
  • Profile Information

To Provide Our Services

  • Identifiers
  • Commercial Information
  • Sensory Information
  • Profile Information
To Communicate With Current And Prospective Recipients Of Our
  • Identifiers
  • Internet Or Other Electronic Network Activity Information
  • Sensory Information

To Protect Against Malicious, Deceptive, Fraudulent, Or Illegal Activity

  • Identifiers
  • Characteristics of Protected Classifications Under California or Federal Law
  • Commercial Information
  • Sensory Information
  • Internet or Other Electronic Network Activity Information

To Audit Company’s Interactions, Transactions, And Legal Compliance

  • Commercial Information
  • Internet or Other Electronic Network Activity Information

To Undertake Internal Research For Technological Development And Demonstration

  • Identifiers
  • Internet or Other Electronic Network Activity Information
  • Characteristics of Protected Classifications Under California or Federal Law
  • Commercial Information
  • Sensory Information
  • Profile Information

To Undertake Activities To Verify Or Maintain The Quality Or Safety Of Our Services, And To Improve, Upgrade, Or Enhance Our Services

  • Commercial Information
  • Sensory Information

For Service Training

  • Identifiers
  • Payment Information
  • Product or Service Usage Information
  • Commercial Information
  • Sensory Information
  • Internet or Other Electronic Network Activity Information
  • Profile Information

Short-term, Transient Use

Sources Of Personal Information Collected

In the last 12 months, Company collected the following categories of Personal Information about California Consumers from the following sources:

  • Directly From California Consumers: (a) Identifiers; (b) Characteristics of Protected Classifications Under California or Federal Law; (c) Commercial Information; (d) Sensory Information; (e) Professional or Employment-Related Information; (f) Non-Public Education Information; (g) Profile Information.
  • Data Collection Technologies (described above): Internet Or Other Electronic Network Activity Information.

Disclosure Of Personal Information To Third Parties

In the last 12 months, Company may have disclosed the following categories of Personal Information about California Consumers to the following categories of third parties for a business, commercial or legal purpose:

Category of Personal Information Category of Third Party
All Categories of Personal Information Collected
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Internet or Other Electronic Network Activity Information
  • Service Providers, including providers of Data Collection Technologies, providers of data analytics services, and website providers
  • Third-party advertising networks

No Sale Of Personal Information

In the last 12 months, Company has NOT sold California Consumers’ Personal Information and Company shall not sell California Consumers’ Personal Information.

Your California Privacy Rights

Right to Know

California Consumers have the right to submit a verifiable request to know:

  • The categories and specific pieces of Personal Information that Company has collected about them;
  • The categories of sources from which Company collected the Personal Information;
  • The categories of Personal Information that Company sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and
  • The business or commercial purposes for Company’s collection, disclosure, or sale of the Personal Information.

Right To Delete

  • California Consumers have the right to submit a verifiable request for deletion of their Personal Information that Company has collected from the Consumer.

Request Update

  • California Consumers can also submit a verifiable request updates to their Personal Information that Company has collected from the Consumer.

Right to Opt Out of Sale of Personal Information

  • California Consumers have a right to opt-out of the sale of the Personal Information. However, as stated above, Company does not and will not sell Personal Information.
How to Exercise Your Rights

Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request and validate the request itself. California Consumers can exercise their rights in the following ways:

Requests By Authorized Agents

You may designate an authorized agent to exercise your right to know, your right to delete and request updates by submitting to us a completed “Authorized Agent Designation” form. You can obtain the designation form by writing to:
ManpowerGroup Inc.
Attn: General Counsel
100 Manpower Place
Milwaukee, WI 53212

If an authorized agent submits a request on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity.

How We Will Verify Your Requests

The processes that we follow to provide access to our "Secure Online Portal" and verify the identity of the person making a request to know, update or delete data about whom we have collected personal information are described below.

All consumer requests require multiple verifications to confirm both the email of the consumer making the requests and the "Secure Online Portal" access requested.

For each new request via our "Online Request Form", a consumer will receive an email requesting confirmation of their email address to enable access to our "Secure Online Portal". Once the "Secure Online Portal" is accessed, we will require that you re-authenticate yourself by completing a "Request an Access Code" process and entering the code sent to enable access to the "Secure Online Portal" and two-way communication with the Manpower Group Privacy team.

You are responsible for protecting the security of your credentials and codes for the "Secure Online Portal" so please do not share your access credentials or codes with anyone. If we suspect fraudulent or malicious activity on or from your account, we will not respond to any request until we have been able to confirm, through further verification procedures, that you made the request.

As an additional access point, a phone number is available for any assistance you may need in making your request via the "Online request Form" and "Secure Online Portal"

All Consumer Requests require verification of a consumer’s identity to confirm they are who they say they are and additional documentation if you are submitting requests on behalf of someone else.

Under the CCPA, a business is only required to respond to requests that are "Verifiable Consumer Requests". A verifiable consumer request is defined as a request that is made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that the business can reasonably verify to be the consumer about whom the business has collected personal identifiable information.

  • All Consumer Requests for Personal Information:
    • Consumer will need to provide one of the following to verify their personal identity: Scanned Driver License, Birth Certificate, Utility Bill or Passport when making a request for themselves.
    • Consumer will additionally need to provide a scanned Power-Of-Attorney if the consumer request is on behalf of someone else for any reason.
  • All Consumer Update Requests To Personal Information also require:
    • Consumer will additionally need to provide proof of the changes requested.

We have implemented the following additional procedures when verifying the identity of Consumers making requests:

  1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process. We will not use that information for any purpose other than verification.
  2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity and process your request.
The Company’s Non-Discrimination Policy

California Consumers have the right not to be subject to discriminatory treatment by Company for exercising their privacy rights under the California Consumer Privacy Act, and Company will not discriminate on that basis. However, Company may charge a California Consumer a different price or rate or provide a different level or quality of goods or services if the difference is reasonably related to the value provided to the California Consumer by the Consumer’s Personal Information. If Company does so, it will provide Consumers with any legally required notice.

Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes:

Under California law, California Consumers can request information from us about whether we have disclosed Personal Information to any third parties for the third parties' direct marketing purposes. We will not sell your Personal Information to, or share it with, third-party companies for their direct marketing purposes without your consent. California Consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.

Your 'Do Not Track' Browser Setting

Company’s websites collect personally identifiable information about your online activities over time and across third-party websites or online services. Through Company’s advertising networks, other parties may also collect personally identifiable information about an individual’s online activities over time and across different websites when an individual uses Company’s websites. Company’s websites do not support the Do Not Track browser setting.

Third-Party Links And Services

We provide links to third party websites operated by organizations not affiliated with Company. We do not disclose your Personal Data to organizations operating such linked third-party websites. We do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each and every website that you visit. This Privacy Policy applies solely to information collected by Company through the Services.

Minors Under 13 Years of Age

We respect the privacy of children. Our Services are not designed to attract an audience younger than thirteen (13), and we do not knowingly collect Personal Information from children under thirteen (13). If you are under the age of thirteen (13), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected information from your child under the age of thirteen (13), and we will work to delete it.

For More Information

For questions or concerns about Company’s privacy policies and practices, please write to:

ManpowerGroup Inc.
Attn: General Counsel
100 Manpower Place
Milwaukee, WI 53212
Changes To This California Privacy Policy

From time to time, we may modify this California Privacy Policy to accommodate new technology, industry practices, regulatory requirements, or for other purposes. If we make material changes to this California Privacy Policy that would impact your continued use of our Services, we will make reasonable efforts to notify you of such changes (including through email, push message, and/or by posting a notice directly to your account), and may also ask you to affirmatively consent to the changes at the time of your next login to the Services. By continuing to use the services after such notice and/or consent, you agree to the terms of the California Privacy Policy as modified. If you do not agree with our changes to the California Privacy Policy, your sole and exclusive remedy will be to discontinue use of the Services and this website.

4825-1847-8546.1 081265.1072