Data Annotation California, United Kingdom and European Union Privacy Notice for Independent Contractors

Last Updated: June 6, 2025

1. Introduction

Data Annotation, and each of its affiliates (collectively known as "Data Annotation"), provide this Privacy Notice ("Notice") to describe our privacy practices with respect to our collection and Processing of Personal Information or Personal Data (collectively "Personal Information") as defined and as required under the California Consumer Privacy Act 2018 ("CCPA"), the EU General Data Protection Regulation ("EU GDPR") and the UK Data Protection Act 2018 (the "UK GDPR") (collectively, the EU and UK GDPR's will be referred to as the "GDPR").

This Notice applies only to independent contractors resident in the State of California from whom we collect Personal Information and independent contractors whose Personal Information is Processed in the UK or within the EU ("Independent Contractors").

For the purposes of this Notice, "Process" means any operation or set of operations which is performed on Personal Information, whether or not by automated means, including accessing, retrieving, collecting, recording, organizing, structuring, storing, adapting or altering, consulting, modifying, using, disclosing by transmission, transferring, disseminating or otherwise making it available, aligning or combining, restricting, erasing or destroying.

2. The Types of Information We Collect From or About Independent Contractors

We may collect, Process, store and transfer Personal Information from or about you in a variety of different situations and using a variety of different methods, including, but not limited to, on our website, through our portal, your mobile device, through email, through instant messaging, through written applications, and/or over the telephone and where you interact with us directly or indirectly when providing your services.

Generally, we may at various times in the course of your provision of services to Data Annotation, collect, receive, maintain, and use the following categories of Personal Information for any of the purposes listed below in this Notice and to the extent permitted under applicable law:

Category	Examples
A. Personal Identifiers	Name, alias, date of birth, postal or mailing address, email address, telephone number, social security number, driver's license or state identification card number, passport number, username and password for Data Annotation accounts and systems, certain geolocation data such as your IP address and/or GPS location, latitude & longitude.
B. Professional Information	Tax forms/1099 forms, information related to services provided by Independent Contractors, including but not limited to statements of work, information on prior convictions or offences (where relevant), and your Data Annotation account log- in, in combination with any required security or access code, password, or credentials allowing access to the account).
C. Protected Classifications (also known as "Special Category Data")	Only if necessary, your race, gender, age, trade union membership or health information. Please note, we will only Process and collect special category data if we have a lawful basis for doing so.
D. Financial Information	Invoices billed to Data Annotation, payments made by Data Annotation, other financial account information.
E. Internet Activity	Such as browsing history, search history, and interactions with our website and applications.
F. Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information	Inputs (e.g., images, photos, videos, and audio files that you may upload) and outputs (i.e., AI tools outputs, voice models, face models).
G. Biometric Information	Such as facial recognition data.
H. Inferences	Inferences drawn from any of the information identified above to create a profile about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information does not include:

• Publicly available information from government records.
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the Independent Contractor or from widely distributed media.
• Information made available by a person to whom the Independent Contractor has disclosed the information if the Independent Contractor has not restricted the information to a specific audience.
• Deidentified or aggregated information.

3. How We Process Personal Information and Sensitive Personal Information

Your Personal Information shall be Processed in a manner that is adequate, relevant, and not excessive in relation to the intended business purpose(s) of such Processing. Where required, we always have a legal basis for collecting and using your Personal Information. We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We use and Process Personal Information in the following ways:

1. To ensure the security of our facilities, network, and information systems.
2. To manage and operate our business, including accounting, auditing, and other internal functions.
3. Monitor and improve our services to develop our AI models.
4. Marketing our Services to our clients.
5. Analyzing our Services and your use of the Services.
6. To comply with labor and employment laws, tax laws, and other applicable regulations.
7. To respond to law enforcement.

From time to time, Data Annotation may need to make Personal Information available to other unaffiliated third parties. Third party service providers, our business partners and professional advisors are expected to protect the confidentiality and security of Personal Information, and only use Personal Information for the provision of services to Data Annotation and its affiliates, and in compliance with applicable law.

We will not collect or Process additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. How we Disclose your Personal Information

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract, we further restrict the contractor and service provider from selling or sharing your Personal Information as defined under the CCPA and the GDPR.

In the past twelve (12) months we have disclosed your Personal Information to the following third parties:

1. Category A (Personal Identifiers): Services providers engaged in data analysis, operating system and security providers. Government entities and law enforcement as necessary.
2. Category B (Professional Information): Service providers engaged in contractor sourcing.
3. Category C (Protected Classifications): Services providers engaged in data analysis, operating systems and security providers.
4. Category D (Financial Information): Service providers engaged in accounts payables and receivables.
5. Category E (Internet Activity): Service providers involved in security and analytics.
6. Category F (Audio and Similar Information): Service providers engaged in operating systems and data analysis.
7. Category G (Biometric Information): Service providers engaged in operating systems and data analysis.
8. Category H (Inferences): Services providers engaged in data analysis, operating system and security providers. Government entities and law enforcement as necessary.

5. Retention of your Personal Information

Any Personal Information collected by us or our service providers and contractors will be retained during the period of the person's active engagement as an Independent Contractor; and during the post-engagement period as long as retention is reasonably necessary and proportionate to achieve the purposes for which it was collected including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

6. Your Rights in Connection with Personal Information

Depending on the applicable data protection and privacy laws and regulations where you are located or where your Personal Information is Processed, you may be entitled to exercise some or all the below privacy rights:

1. Right to know: You have the right to request information about the categories and specific pieces of Personal Information we have collected about you.
2. Right to request access: You have the right to request access to your Personal Information (commonly known as a data subject access request in the UK and EU).
3. Right to request correction: You have the right to request correction of the Personal Information we hold about you.
4. Right to delete: You have the right to request the deletion or removal of Personal Information we have collected from you where there is no good reason for us continuing to process it, subject to certain exceptions.
5. Right to request the restriction of processing of your personal information: You have the right to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.
6. Right to transfer: You have the right to request the transfer of your Personal Information to another party.
7. Right to opt-out of Sale or Share: You have the right to opt out of the Sale or Sharing of your Personal Information. However, we do not sell or share your Personal Information in this context.
8. Right to opt-out of Automated Decision Making: In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
9. Right to limit the use of Sensitive Personal Information: Under certain circumstances, you have the right to limit the disclosure of your Sensitive Personal Information.
10. Right to non-discrimination: You have the right to not be discriminated against for exercising your CCPA or GDPR rights.
11. Right to withdraw consent: in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
12. Right to object to processing: You have the right to object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.

Please note that if you exercise certain California rights while you are employed as an Independent Contractor, this may prevent you from using the Services due to the nature of our business.

7. International Data Transfers

Data Annotation is a global company and may transfer Personal Information to entities, affiliates and service providers located in such jurisdictions as the United States, the EU and the UK. Not all jurisdictions have the same level of protection as your country of residence may provide. However, we shall not transfer Personal Information to a country or territory outside the jurisdiction in which it was Processed, except in accordance with the requirements prescribed under relevant data protection laws. We may transfer or provide access to Personal Information across jurisdictions and entities in accordance with our data sharing agreements which are aligned with applicable data protection laws.

8. Contact Details

If you want to exercise your rights under the CCPA or GDPR, please contact us at [email protected].

We will respond to your request in accordance with the applicable law(s). You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

9. Complaints

We hope that we will be able to address your concerns regarding the Processing of your Personal Information. However, if you have any unresolved concerns, you have the right to claim to the data protection authority in your jurisdiction. The UK regulator for data protection issues is the Information Commissioner's Office (https://ico.org.uk/) and the European regulator for data protection issues is the European Data Protection Board (https://www.edpb.europa.eu/edpb_en).

10. Updates to this Notice

This Notice is subject to periodic revision and updated versions are effective when posted. The current version of this Notice will be posted or available on our intranet. We may also notify you in other ways from time to time about the Processing of your Personal Information.

11. Questions

If you have questions or concerns about this Notice, please contact us at [email protected].