PARAMOUNT WORKPLACE PRIVACY NOTICE

Paramount is a leading global media and entertainment company that employs and engages workers worldwide. We collect information on individuals who are currently or formerly a part of our workforce — such as employees, officers and directors, interns, contractors, and other individuals who perform work for us, whether employed by us or not, and their dependents, beneficiaries, and emergency contacts. We also collect information on individuals who we have contracted to work for us or on our third parties’ productions. We refer to this broader group of individuals as ‘workers’ for ease.

Nothing in this notice is intended to create an employment relationship between Paramount and any non-employee and it does not create any contractual rights or obligations. While this notice is global in nature, our goal is to meet the requirements in each country where our workforce is located.

Third parties involved in a production may independently collect your personal information directly from you and may use it in accordance with their own privacy policies, with which you should familiarize yourself. Additional notices about our information practices and choices, such as for certain production activities, may apply to you, and will be made available to you depending on the context of your relationship with us. We invite you to read this notice together with any other applicable privacy notices.

This notice does not apply to information collected when you interact with our services as a consumer or visitor to Paramount products and services. To learn about our information practices when you are a consumer, you can review our privacy policies available on Paramount branded properties.

Trust is a cornerstone of our mission at Paramount. We are committed to gaining and maintaining your trust by following a core set of privacy principles: 

• Transparency – We will tell you what information we collect about you and how we use it. 

• Access – When possible, and when required by law, we will provide you with access to the information that we collect about you.

• Security – We will protect your information with reasonable security measures.

• Accountability – We will take responsibility for the secure processing of your information and do our best to address any concerns or questions that you have about how we process your information.

What Personal Information We Collect About You & Why We Use It

Paramount collects a variety of information about you, which we use to support our human resources and other legitimate business and commercial purposes, including establishing, maintaining, and terminating your employment or other service relationship. For purposes of this notice, we refer to this information as “personal information” or “personal data” (each as defined under applicable law). Below, we list categories of the personal information we may collect and the purposes for which we may use it.

• Contact Information (such as your name, telephone number, photo, email address, physical address, and the name, telephone, email address and physical address of your designated emergency contact) in order to contact you with relevant information, to contact you or others on your behalf for all the purposes identified in this notice, to facilitate communication and collaboration among workers, to confirm worker eligibility under applicable union agreements, and to notify you or your next of kin in the event of an emergency, work-related accident or illness. 

• Payroll and Benefits Information (such as bank account details, payroll records and information about your compensation, name and date of birth for compliance check purposes, tax status information, pension and other retirement benefits information, social security numbers, tax identification number or other government-issued identification number of you, your spouse/domestic partner, or other family member, information on attendance, vacation, medical, parental/family, or other leave) in order to administer aspects of your employment, salary, and compensation; paying and administering your salary, bonus, incentive plans, family leave pay, sick pay, insurance, and other benefits, and reviewing or making decisions about your employment.

• Identity Verification Information(such as your name, date of birth, address, social security number) in order to administer aspects of your employment or engagement and to comply with legal obligations and/or company policies, including preventing corruption and crimes and confirming your legal work status.

• Background Check Information(such as your job history, qualifications and previous renumeration as well as credit, criminal record, social media and adverse media checks, subject to local law) in order to verify information provided and to evaluate your suitability for a role, information used in connection with your right to work, and other information necessary for your role, such as event credentialing.

• Demographic Information and/or Protected Classifications (such as your age, gender, race, ethnicity, national origin, religion, sexual orientation, political opinions, trade union membership, veteran status, criminal convictions and offenses in accordance with applicable law, disability status and related information, and pregnancy) in order to comply with legal obligations and/or company policies, including record-keeping and reporting required by law and/or company policy, ensuring meaningful equal opportunity monitoring and reporting and support diversity initiatives, and benefits administration. 

• Security and Compliance Information, Records of IT and Systems Use (such as CCTV footage, virtual meeting video and audio recordings, information about your use of our IT, business systems, collaboration tools, company networks, and devices (whether owned by Paramount or through a service provider, such as a cloud computing company), s your communications on our systems, passwords, records of swipe and similar building entry cards, and, in limited cases, output of facial recognition technology, our networks, systems and other tools, to comply with legal obligations and/or company policies, to monitor use of IT systems and other electronic resources, to conduct internal investigations or audits, to maintain improve, verify or maintain the quality, safety, security and integrity of our IT, business systems, networks, and devices and improve or upgrade them, to facilitate remote working, and to maintain and improve cybersecurity and physical security. 

• Performance Management Information (such as performance appraisal information submitted about or by you, information about your compliance with Paramount policies, information about disciplinary allegations, and investigations and processes relating to grievances and complaints in which you may be directly or indirectly involved) in order to manage certain aspects of your employment performance and development.  

• Information Relating to Your Employment Relationship and Terms (such as information about the terms and dates of your employment, details of union representation, and deductions of contributions) in order to assist with legal compliance, payroll administration, benefits administration, and providing references in connection with your finding new employment.  

• Information Relating to the Work you Do for Us (such as information about your role, your travel arrangements, audio/video recordings for performers, and emails or other documents created by you or relating to you) for our day-to-day business operations, compliance with legal obligations or company policies.  

• Health Information  (such as information about your medical condition, workplace injuries, or disabilities) to the extent necessary to comply with our legal obligations, such as to accommodate disabilities, to assess risks to health and safety in accordance with applicable law, for purposes of workers’ compensation, for occupational health surveillance, compliance, and record-keeping as required by law, to conduct fitness-for-duty examinations as legally permitted, to administer leaves of absence and sick time, and to respond to your medical emergency.

• Information relating to pandemics and other health emergencies (such as information about your health-related status, vaccination status, and exposure to illness) to help us provide a safe workplace and/or comply with legal obligations or company policies, managing employee leave and accommodations, including record-keeping required by law or company policy, for insurance claims (which may involve disclosures to insurers and others), and for use in decisions about staffing needs. We may do the following in relation to Covid-19 (or similar health emergencies): 

  • request information about whether you have had symptoms of the virus, close contact with confirmed cases or traveled to high-risk areas, and whether you would be considered clinically vulnerable or clinically extremely vulnerable;

  • conduct temperature checks before allowing entrance to our premises; 

  • ask you to be tested for the virus before allowing entrance to our premises; and/or 

  • request information about vaccination status. 

• Any Other Information You Provide Us in the context of your work for us in order to administer aspects of your employment or other relationship with us, including by way of employee surveys, or to comply with legal obligations and/or company policies including without limitation reviewing and managing your performance.

In the course of employment, you may be required to provide us with information for other purposes such as sick pay and family rights (e.g. parental leave and pay) or in order to carry out your job role (such as for credentialing purposes).  If you do not provide information that you are required by law or contract to give us, you may lose benefits or we may decide not to employ you or end your contract, subject to applicable law or the terms of such contract.  If you have concerns about this in a particular context, you should speak to HR or your Paramount business contact.

We may also use your information for other legitimate business purposes, such as: assessing or executing mergers, acquisitions, divestitures, or business transfers, and managing potential and actual claims, disputes, disciplinary proceedings and other investigations. 

Where the Personal Information Comes From

We collect information about you in a variety of ways. Your information comes from you or your representatives, third parties (such as job references, business partners, professional organizations, staffing agencies, insurance companies), public internet sources (such as public social media profile), public records, service providers, your manager or other colleagues, affiliated or acquired companies, or our IT systems or through automated technologies on our electronic resources, surveillance/recording technologies (such as video surveillance, voicemail technologies and audio recording technologies with consent to the extent required by law), collective bargaining processes, and government or administrative agencies.

Retaining Your Personal Information

We retain your personal information for the time period necessary to achieve the purposes described in this notice, unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies. In general, we will keep your information for the duration of your employment and for a period afterwards.

Who We Share Your Personal Information With & Why

We may share your personal information within the Paramount family of companies.  We may share your information with the Paramount family of companies and Paramount personnel for the purposes described in this notice. This includes to your managers, HR and other administrators for employment, administrative and management purposes as mentioned herein.

We may share your personal information in connection with a corporate transaction.  As noted above, we may disclose or transfer your personal information as part of, or during negotiations for, any purchase, sale, lease, merger, or any other type of acquisition, disposal, or financing involving a Paramount entity or brand. Any sharing of personal information in connection with a corporate transaction will always be subject to a customary confidentiality agreement between the parties. 

We may share your personal information with service providers and contractors who perform services on our behalf or that are necessary for our business purposes.  We may share your personal information with service providers and contractors that provide us with professional advice, business support, perform services on our behalf or in connection with carrying out our business— such as payroll and benefit service providers; insurers; vendors; information technology providers;  professional advisors such as lawyers and accountants; occupational health and medical service providers; background check providers; and  in connection with productions, production companies and their staff; marketing partners and campaigns; and to provide you with appropriate credit.  These service providers and contractors are allowed to use your information to help in connection with your employment or service for us and not for any other purpose.

We sometimes share your personal information with business partners or other third parties. We may disclose your information to a business partner, such as a distribution partner of a new product or service with which you will be working, or other third parties, such as a professional organization for award recognition.

We may share your information with government or administrative agencies. We may disclose your information to government or administrative agencies as required or permitted by law. For example, we may provide your information to labor agencies to respond to unemployment or disability insurance claims.

In some cases, we may disclose your information to the public. We disclose information to the public in accordance with industry practice and applicable law. For example, credits for a production are publicly posted.

We may share your information with labor unions. We may disclose your information to a union or other similar organization that collectively represents workers if it represents you or with your consent.

We may share your information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share your information when it is necessary for us to comply with applicable law or legal process, to respond to legal claims, or to protect our rights or the property or personal safety of our workers, users or the public. 

We may share your information for reasons not described in this notice. We will tell you before we do this if reasonably practicable. 

Protecting Your Information

We use reasonable security measures. We have adopted commercially reasonable technical, administrative, and physical security procedures to help protect your information from loss, misuse, unauthorized access, and alteration.  

Changes to this Notice

From time to time, we may change this notice to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our intranet, or by other means, consistent with applicable law. 

Contact Us 

If you have any questions about this notice, you may contact us by visiting the Privacy Rights Center, completing the relevant form and selecting ‘General Privacy Request’.

ADDITIONAL INFORMATION FOR WORKERS WHO ARE CALIFORNIA RESIDENTS

If you are a resident of California, the following additional information applies to you.

Personal Information Collected About California Residents

The following are categories of personal information that we may collect (and may have collected during the 12-month period prior to the Last Modified date of this notice) about you, your dependents or beneficiaries, or your emergency contacts, as well as examples of the types of personal information that may be collected (or may have been collected):

We may have collected data from the following sources:

• Directly from you (e.g., in your application, assessments, surveys, or during your relationship with us)

• Services providers (e.g., law firms)

• Third Parties (e.g., job references, business partners, professional organizations, staffing agencies, insurance companies)

• Affiliated Companies

• Public Internet Sources

• Public Records

• Automated Technologies

• Surveillance/recording technologies installed by the Company (e.g., video surveillance in common areas of the Company’s facilities, voicemail technologies and audio recording technologies with consent to the extent required by law)

• Labor processes

• Union agreements

• Government or administrative agencies

• Acquired company

We may use your personal information for the purposes described in “What Information We Collect About You & Why We Use It” section of this notice.

Personal Information Disclosed for a Business Purpose to Third Parties

The categories of personal information listed above may be disclosed for a business purpose to the categories of third parties listed above in the section titled “Who We Share Your Information With & Why”.

Retention

We retain your personal information as described in “Retaining Your Information” section of this notice.

Your Privacy Rights And How To Exercise Them

If you are a resident of California, you have certain rights regarding your personal information, which include: 

• Right to Know. You have the right to submit a verifiable request for specific pieces of your personal information we obtained from you. In addition, you have the right to know the categories of personal information collected about you, the categories of sources from which we collected your personal information, the categories of third parties to whom your personal information is disclosed, and the categories of personal information we disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

• Right to Delete. You have the right to submit a verifiable request for the deletion of personal information you have provided to us.

• Right to Correct. You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by us, considering the nature of the personal information and the purposes of processing the personal information.

• Non-discrimination. We will not unlawfully discriminate or retaliate against you for exercising your rights described above.

Sensitive Personal Information. We use sensitive personal information as necessary for the direct purposes relating to your employment or other service relationship, as applicable. We do not collect or process sensitive personal information for purposes of inferring characteristics about individuals.

Sale and Sharing of Personal Information. We do not sell your personal information nor disclose your personal information for cross-context behavioral advertising.

Deidentified Information. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

How to Exercise Your Rights. You or your authorized agent may submit a request to exercise any of the above rights by visiting our Privacy Rights Center and completing the form relevant to your request or by calling us at +1(888)300-2638. If you are currently a member of our workforce with access to Paramount corporate applications, you may have self-service tools available to you to exercise any of the above rights.

How We Will Verify Your Request. We may require additional information to verify your identity or to verify that your authorized agent has the authority to make the request on your behalf.  The verification process may differ depending on the nature and type of request that is submitted. If we cannot verify your identity or your authorized agent’s authority to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot complete your request.

ADDITIONAL INFORMATION FOR WORKERS LOCATED OUTSIDE OF THE UNITED STATES

If you are located outside the US, including in the European Economic Area (EEA), United Kingdom (the UK), and Switzerland, the following additional information applies to you, except as otherwise noted in the INTERNATIONAL SUPPLEMENTS.   

Who is the Data Controller of Your Personal Data 

The entity set out in the International Supplement for your jurisdiction will be a data controller of your personal data (as defined under applicable law). In many cases our US and UK entities (including Paramount Inc.) will also be data controllers of your personal data, as well as other Paramount entities with whom your personal data is shared from time to time, and as set out in this notice.   

Legal Grounds for Processing Personal Data 

Under applicable data protection law, there are various grounds on which we can rely when processing your personal data.  In some contexts, more than one ground applies.  The grounds for processing are as follows: 

• Contract: this is processing necessary for performance of a contract with you or to take steps at your request to enter a contract. This covers carrying out our contractual duties and exercising our contractual rights. 

• Legal Obligation: this is processing necessary to comply with our legal obligations. The processing is necessary for ensuring we perform our legal and regulatory obligations.  For example, providing a safe place of work, complying with health and safety laws, or avoiding unlawful discrimination. 

• Legitimate Interest: this is processing necessary for our or a third party’s legitimate interests. We or a third party have legitimate interests in carrying on, managing, and administering our respective businesses effectively and properly and in connection with those interests processing your data.  Where we rely on legitimate interests, we consider: 

  1. what our legitimate interest is – these are set out in the table below; 

  2. whether the processing is necessary to achieve it (i.e., whether it is proportionate); and 

  3. whether it can be balanced against individuals’ interests, rights, and freedoms (via the protections described in this notice).   

Where this test is not met, we do not rely on legitimate interest. This notice serves as a record of our legitimate interest assessment. 

• Consent: this is where you have given specific consent to processing your personal data. In the UK and EU, processing of your data in connection with employment is generally not conditional on your consent.  But there may be occasions where we do specific things for which we require your consent. In certain jurisdictions we will ask for consent as the basis for processing certain of your personal data.  

Additional legal bases may apply in your jurisdiction.   

Processing Special Personal Data 

Where necessary in your jurisdiction, if we process special personal data about you (for example, storing your health records to assist us in ensuring that we provide you with a healthy and safe workplace, or processing personal data relating to diversity monitoring) we will also make sure that one or more of the grounds for processing special personal data applies. Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by certain privacy law, including EU and UK privacy law, to be “special” or “sensitive” personal data. Data relating to criminal records or offences is treated in a similar way and, for purposes of this notice, included in this definition.  In some jurisdictions a different term may be used to describe data warranting special protection. However, the remainder of this notice uses the term “special” personal data for ease.   

 In outline, these additional grounds for processing include:   

• Processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law or collective agreement;  

• Processing relating to personal data about you that you have made public; 

• Processing being necessary for the purpose of establishing, making or defending legal claims; 

• Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity; and 

• Processing based on us having received your explicit consent (although please note as set out above that, in general, processing of your personal data in connection with employment is not conditional on your consent in the EU or UK).   

Further Information on the Personal Data We Process and Our Purposes 

Examples of the personal data and the grounds on which we process your personal data are described in the table below. Although these examples represent a comprehensive description of the processing we engage in, this list is not exhaustive.  

Sharing Your Personal Data Outside the Group Companies 

We will only disclose your personal data outside our group companies if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.   

We will disclose your personal data if it is necessary for our legitimate interests as an organization or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy).  We may will also disclose your personal data if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.   

Access to Your Personal Data and Other Rights 

You may have certain rights regarding your personal data, which may include: 

• The right to request access to and/or a copy of the personal data we hold about you, including details as to how we process this personal data; 

• The right to object to or restrict our processing of your personal data; 

• The right to request that your personal data be erased from further use; 

• The right to correct, amend, or update personal data you have given us (in some instances, such as on our internal employee portals, you can also do this by logging in and updating your personal data); 

• The right of portability, which allows you to request that we share your personal data with others;  

• The right not to be subject to automated decision making, i.e. a decision made solely by automated processing; and 

• If we have relied on consent as a ground for processing, the right to withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent. If you withdraw your consent, we will provide you with an assessment of how such withdrawal will impact our ability to reasonably support your employment. 

To make a request, complete the relevant form on our Privacy Rights Center. If you are currently a member of our workforce with access to Paramount corporate applications, you may have the ability to use self-service tools in those applications to exercise some of your privacy rights when available in your jurisdiction. The regulator in your jurisdiction may have produced forms to assist you in making a request – where this is the case you can attach these to your request.   We may require you to provide information from which we can confirm your identity. Please note that, while we will carefully assess every request we receive, your rights may differ according to your place of residence and we may not always be required to comply. If we do not comply with your request, we will explain why. 

If you have any unresolved privacy concerns that we have not addressed satisfactorily after contacting us, you may have the right to contact your local data protection authority.  

Journalistic Exemption (in relation to cast, crew, production, and talent) 

Please note that as a result of the nature of the work that you do for us (i.e. working on our or third parties’ productions), on some occasions Paramount and our group companies or third parties will rely on exemptions to data protection rules in relation to journalistic freedom, the right to artistic expression or more generally, the right to freedom of expression (as mentioned in Article 85 of the General Data Protection Regulation and in various jurisdictions’ data protection rules). This can mean that certain parts of the GDPR (including data subjects’ rights) do not apply.  We will rely on similar provisions where applicable in other jurisdictions.  

International Transfers 

In connection with our business and for employment, administrative, management and legal purposes, we will where necessary transfer your personal data across country borders in accordance with applicable law. Such transfers include to members of our group of companies and third-party service providers, including in the US and in other jurisdictions in which we are established. For example, some of the systems that we use in connection with our business and your employment (such as our HR Information system) are hosted in the US.  We will ensure that any transfer is lawful, including putting in place legal safeguards and ensuring that there are appropriate security arrangements. More specifically, (i) for transfers outside the EEA / UK, this includes entering into the relevant official European or UK Standard Contractual Clauses for transfers to third countries with Paramount group entities and third parties located outside the EEA / UK and, where necessary, implementing further measures to ensure the information is subject to equivalent local protection; (ii) for transfers outside of Argentina, we will enter into the applicable official Argentina Model Clauses with Paramount group entities and third parties located outside Argentina when necessary; and (iii) for transfers outside of certain other jurisdictions, where required by applicable law, we apply the substantive requirements of the official European or UK Standard Contractual Clauses.  

If you want further details of any of these safeguards or agreements, please contact us at the email address listed in the “Contact Us” section.  

Argentina

If you are employed, engaged, or reside in Argentina, the following additional information applies.

The local regulator is the Public Information Access Agency (A.A.I.P.)

In addition:

In accordance with Act No. 25,326 (Personal Data law) and Act No. 20,744 (Labor Contract law) we can transfer your personal data without your consent in these specified cases:

• When the transfer is foreseen or authorized by law.

• When the transfer is necessary for the prevention or medical diagnosis, the provision of health care, medical treatment, or the management of health services.

• When the transfer is necessary or legally required for a reason of public interest.

• When the transfer is necessary for the exercise or defense of a right in a legal process.

Australia

If you are employed, engaged, or reside in Australia or are in Australia when your personal data is collected by us, or, regardless of your location, and if your personal data is collected by any of the local Data Controllers listed below, the following additional information applies.

The local regulator is the Office of the Australian Information Commissioner (OAIC).

Workplace surveillance

• Surveillance devices will not be used in the following locations: in changing rooms, toilet facilities, shower, or other bathing facilities;

• Where camera surveillance takes place, the camera will be clearly visible in the place where surveillance is taking place and signs notifying people of the surveillance will be clearly visible at the entrance to the workplace;

• Where computer surveillance takes place, it will be carried out in accordance with local laws and Paramount policy;

• Where tracking surveillance is used in relation to a vehicle (or other thing), there will be a notice visible on the vehicle (or other thing) indicating that it is the subject of tracking;

• Covert surveillance in the workplace will not occur unless authorized by a Magistrate (i.e. for determining whether a worker is engaged in an unlawful activity in the workplace).

Paramount gives notice of the following surveillance which will be carried out in the workplace:

Workers in the Australian Capital Territory may consult with Paramount about the conduct of surveillance.

Special personal data

Not all of the grounds for processing special personal data described in the section of this Notice entitled “PROCESSING SPECIAL PERSONAL DATA” apply to your special personal data. As such, we will only process your special personal data as permitted by law, for example where we have received your consent to do so or the collection is required by law.

Journalistic exemption

The section “Journalistic exemption” does not apply.

Complaints

If we receive a complaint from you in relation to our processing of your personal data, we will investigate the complaint and determine whether a breach of this Notice or the Privacy Act has occurred and what action, if any, to take. Paramount will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is one month unless your query is complex. Paramount expects our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the OAIC:

www.oaic.gov.au

Complaints to the OAIC must be made in writing.

Belgium

If you are employed, engaged, or reside in Belgium, the following additional information applies.

The local regulator is the Data Protection Authority (in Dutch: ‘Gegevensbeschermingsautoriteit’ / in French: ‘l'Autorité de protection des données’).

In addition:

• If we would like to process (reproduce/disclose) your picture, we will ask for your active and explicit consent (by means of a paper consent form or by ticking a box electronically). This does not apply to pictures you have voluntarily provided (such as in your CV, or via chat or video conferencing tools) or if we have another legal basis to process it (e.g. pictures on access badges, the relevant legal basis for which is our legitimate interest in ensuring the security of our premises).

• If we would like to carry out reference checks with third parties, we will ask for your explicit consent and keep you informed when we request information from external organizations and persons.

• Monitoring of diversity and equal opportunities: as there is currently no exception for Belgian companies from the prohibition on processing special personal data as part of a diversity policy, we will not process any special personal data for this purpose unless otherwise permitted under applicable law or will do so on an anonymous basis only.

• When we use CCTV, we will observe the provisions of national collective bargaining agreement no. 68.

• When we monitor e-mail and internet use, we will observe the provisions of national collective bargaining agreement no. 81.

Brazil

If you are employed, engaged, or reside in Brazil, the following additional information applies.

The local regulator is the National Data Protection Authority (in Portuguese: Autoridade Nacional de Proteção de Dados – ANPD), as created by the Law No. 13,709/2018 (LGPD).

In addition:

• We may process special personal data if the processing is necessary for the purpose of preventing fraud and ensuring the safety of the data subject with respect to registering for and authenticating access to our electronic systems.

• Any kind of background checks will be carried out only if strictly necessary in connection with the duties assigned.

• Brazilian data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent.

Canada

If you are employed, engaged, or reside in Canada, the following additional information applies.

The statutory regulator in British Columbia is the Information and Privacy Commissioner.

In addition:

If you send us a request (to the email address provided in this Notice) to access or correct your personal data, we will contact you within 30 days (although it may take us longer to fully respond to your request).

China

If you are employed, engaged, or reside in the People’s Republic of China, the following additional information applies.

The local regulators are the Cyberspace Administration of China (CAC), Industry and Information Technology Department Bureau and Public Security Bureau.

In addition:

• We do not process personal data without your consent. The purpose of the collection of personal data, the scope of the information collected, and the individuals or entities with which the data will be shared and accessed are generally listed in the above Notice. If we collect personal data from a third party, we will do so with your consent.

• We will only transfer your personal data outside of China with your prior express consent or after applying security measures to your data, such as anonymizing your personal data prior to the transfer.

• As noted above, your activity on the company’s computers, phones, and other devices, as well as access and usage of emails and documents, may be monitored for the purposes of compliance with our policies and rules. However, we will not monitor or check private electronic communications or any other private data in your personal systems (e.g. personal e-mail accounts, instant messaging applications, etc. which are registered in your name), unless with your explicit consent.

• As noted above, we may require you to provide emergency contact information and information of your next of kin and you are responsible for getting necessary consent from these individuals whose personal data is provided to us and agree that, when disclosing the personal data of these individuals, you will be acting on their behalf.

Czech Republic

If you are employed, engaged, or reside in the Czech Republic, the following additional information applies.

The local regulator is Úřad pro ochranu osobních údajů.

In addition:

The following examples of the personal data that we process and our grounds for processing them differ from those provided in the Notice above:

• Before you begin your employment, we only process personal data relevant to the application process, i.e. personal data relating to qualifications, work experience, skills, and knowledge.

• Czech data protection legislation does not allow for the processing of special personal data for equality and diversity purposes.

• Generally, we will not process any information on:

(a) pregnancy;

(b) family and property situation;

(c) sexual orientation;

(d) national/ethnic origin;

(e) trade union organization membership;

(f) membership of political parties or movements;

(g) religion or confession; or

(h) criminal records.

However, with the exception of (c), (d), (e), (f) and (g), we may process the above in rare cases where there is an objective reason for doing so relating to your role (for example if you are pregnant in relation to your parental leave or if you are responsible for large amounts of money, information about your criminal record may be requested). We may also process such personal data in cases where we are legally required to do so.

• As specified above, your activity on our intranet, internet, access logs, web history and searches, as well as access and usage of emails and documents, may be monitored for the purposes of compliance with our policies and rules, which is in the legitimate interest of Paramount and based on a serious reason related to the special nature of the employer's activity. However, any monitoring is conducted in accordance with Czech legislation including minimization of the monitoring. When accessing emails we will check (based on relevant identifiers – for example, recipient, subject, etc.) to ensure that the email is not of a private nature, and in the event that we nevertheless come upon a private (i.e. non work related) email (or any other private data) we will not further monitor or check the contents of such communication or data.

Denmark

If you are employed, engaged, or reside in Denmark, the following additional information applies.

The local regulator is the Datatilsynet (the Danish Data Protection Agency).

https://www.datatilsynet.dk/

In addition:

• If we would like to process (reproduce/disclose) your picture for marketing or customer/client relations purposes, we will ask for your consent. This does not apply to pictures you have voluntarily provided (such as in your CV, chat, or video conferring tools) or if we have another legal basis to process it.

• Danish legislation does not include any specific provisions allowing the processing of personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes except for age, gender, and disability, in which case we will ask for your consent, or we will do so on an anonymous basis only.

• As specified above, your activity on the company’s intranet, internet, access logs, web history and searches, as well as access and usage of emails and documents, may be monitored for the purposes of compliance with our policies and rules, which is in the legitimate interest of Paramount. However, in the event we come upon a private (i.e. non work related) electronic communication or any other private personal data which is marked as such, we will not monitor or check the contents of such communication or personal data, unless we have a reasonable suspicion that the communication was marked private to hide any wrongdoing (for example disclosure of our confidential information).

Finland

If you are employed, engaged, or reside in Finland, the following additional information applies.

The local regulator is Tietosuojavaltuutettu (the Data Protection Ombudsman) (https://tietosuoja.fi/en/home)

In addition:

• We only process personal data that is directly necessary for your employment relationship.

• We primarily collect personal data directly from you. If we collect personal data from elsewhere, we will do so only with your consent. In any event, we will notify you of the collection of your personal data from such external sources prior to making any decisions based on that information.

• We do not retrieve or open your e-mails, private files or other files containing your communications, unless you have expressly consented to this or it is specifically permitted by law.

• When monitoring our systems to check compliance, we do not access your emails or web browsers' logs or monitor your internet use.

• We only process information concerning your health if specifically allowed by law. In any case, all information concerning your health is retained separately from your other personal data we process.

• CCTV surveillance will be used only where the legal requirements for its use are fulfilled, including, but not limited to, any prior cooperative and consultative procedures. The personal data collected will be used only for the purposes for which the CCTV was originally implemented.

France

If you are employed, engaged, or reside in France, the following additional information applies.

The local regulator is the Commission Nationale de l’Informatique et des Libertés (CNIL).

In addition:

• The French data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

• Under French data protection legislation, you have the right to give instructions on what happens with your personal data after your death.

Germany

If you are employed, engaged, or reside in Germany, the following additional information applies.

The local regulator is:

In addition:

In Germany, personal data will be processed where necessary under Section 26 of the Federal Data Protection Act ("Bundesdatenschutzgesetz") and on the following legal bases:

• For employment-related purposes where necessary for hiring decisions or, after hiring, for carrying out or terminating the employment contract or to exercise or satisfy rights and obligations laid down by law or by collective agreements or other agreements between us and the staff council.

• To detect crimes only if there is a documented reason to believe you have committed a crime while employed, and where the processing of such personal data is necessary to investigate the crime and is not outweighed by your legitimate interest in us not processing the personal data (and in particular where the type and extent of the data processing are not disproportionate to the reason).

• If your personal data is processed on the basis of consent, we shall take into account whether you are able to freely give it. This may include where there is an economic advantage for you, or where we are pursuing the same interests. Consent will normally be requested in written or electronic form unless a different form is appropriate because of special circumstances. Where we rely on consent, we ensure you are fully informed and you will have the right to withdraw consent.

• Special personal data:

  • If necessary to exercise rights or comply with legal obligations derived from labor law, social security and social protection law, and there is no reason to believe that the you have an overriding legitimate interest in us not processing the personal data. Where we process such personal data based on your consent, we will request the consent specifically. We may also process special personal data on the basis of collective agreements.

  • The German data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

Hungary

If you are employed, engaged, or reside in Hungary, the following additional information applies.

The local regulator is the National Data Protection and Freedom of Information Authority (http://www.naih.hu/).

In addition:

The following examples of the personal data that we process and grounds for processing differ than as provided in this Notice:

• Paramount will not conduct covert monitoring of its employees. In accordance with local laws, Paramount shall always provide prior notice in writing of monitoring by technical means – including by means of this Notice - and shall only conduct such monitoring to the extent necessary for the employment relationship.

• As specified above, your activity on the Company’s intranet, internet, access logs, web history and searches, as well as access and usage of emails and documents, may be monitored for the purposes of compliance with our policies and rules, which is in the legitimate interest of Paramount. However, in the event we come upon private (i.e. non work related) personal data, we will not monitor or check the contents of such personal data.

• Hungarian data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

• Data regarding disability may be processed based on Act CXCI of 2011 to determine the percentage of disabled employees, calculate the amount of the rehabilitation contribution payable by Paramount, and to determine if Paramount is entitled to further allowances.

Ireland

If you are employed, engaged, or reside in Ireland, the following additional information applies.

The local regulator is the Data Protection Commission (www.dataprotection.ie).

In addition:

• Irish data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

• The applicable legislation in Ireland on exemptions to data protection rules in relation to journalistic freedom, the right to artistic expression or more generally, the right to freedom of expression is set out in Section 43 of the Data Protection Act 2018.

• Generally, we do not carry out criminal record checks in Ireland unless this is particularly necessary given your role – e.g. you are going to be working with children or vulnerable adults. We may also require you to complete a self-declaration questionnaire where relevant to a particular role.

• Generally, we do not carry out credit background checks in Ireland, but we may carry out judgment and bankruptcy searches against current or prospective employees where necessary and proportionate, as such databases are accessible by the general public.

Italy

If you are employed, engaged, or reside in Italy, the following additional information applies.

The local regulator is Autorità Garante della Privacy.

In addition:

Italian data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we will generally only process personal data, including special personal data, for these purposes where we have a legal obligation – e.g. in relation to gender and disability reporting – we have your consent; or we do so on an anonymous basis.

Mexico

If you are employed, engaged, or reside in Mexico, the following additional information applies.

The statutory regulator is the National Institute for Transparency, Access to Information and Personal Data Protection (‘INAI’).

In addition:

In terms of the Federal Law on the Protection of Personal Data in the Possession of Private Parties and its Regulations, note that in the event we refuse to respond to an request regarding your personal data rights, or in the case that you disagree with our response, you may file before the National Institute of Transparency, Access to Information and Personal Data Protection the corresponding Application for the Protection of Rights within the deadlines and terms established by chapter VII and other related chapters, as well as the ones relevant from the Regulations to the Law.

Netherlands

If you are employed, engaged, or reside in the Netherlands, the following additional information applies.

The local regulator is Autoriteit Persoonsgegevens. Mailbox 93374, 2509 AJ THE HAGUE. Phone: (+31) – (9)70 88 85 00.

In addition:

• All information concerning the nature of your health is retained separately by a Company Doctor or the Health and Safety service. Except as otherwise indicated to you, Paramount does not have access to information concerning the nature of your health. Unless you have made public your personal data regarding the nature of your health (e.g. telling your colleagues the nature of your illness) we will not process this personal data directly.

• Data regarding nationality, race and ethnic origin may be processed for diversity monitoring / equal opportunities purposes where necessary in order to reduce factual disadvantages related to race or ethnic background. However, we will stop such processing if you ask us to.

• Data regarding disability may be processed for diversity monitoring / equal opportunities purposes in order to meet our legal obligations.

• With regard to other special personal data categories, we will not process this personal data for the purposes of diversity monitoring / equal opportunities purposes or will do so on an anonymous basis only.

Poland

If you are employed, engaged, or reside in Poland, the following additional information applies.

The local regulator is the Prezes Urzędu Ochrony Danych Osobowych (The President of the Personal Data Protection Office), Stawki 2, 00-193 Warsaw, Poland.

In addition:

• Your personal data will be processed and kept for the period of performance of your employment contract, and after the expiration of the contract for the period necessary for us to perform our legal obligations deriving from legally binding provisions. If your personal data is only useful for a short period (for example a record of a holiday request), we will delete it when it is no longer useful (during your employment), in accordance with our retention policies.

• The following provisions of local law determine retention periods for your personal data:

  • regarding employee documentation (dokumentacja osobowa i płacowa) – Polish Labor Code (Kodeks pracy) and the relevant regulations pertaining to employee documentation issued under the Labour Code; and

  • regarding the personal data processed by means of the CCTV – Polish Labor Code.

• Polish data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

Portugal

If you are employed, engaged, or reside in Portugal, the following additional information applies.

The local regulator is Comissão Nacional de Protecção de Dados (CNPD).

In addition:

• We will not collect or process any CCTV images in the interior of spaces reserved to employees, such as dining areas, locker rooms, etc. In any case and when admissible, video surveillance with sound recording will normally only occur upon prior authorization from the local regulator.

• Any personal data recorded by remote surveillance will generally only be used in the context of criminal proceedings. In that situation, such personal data may also be used to establish disciplinary responsibility.

• When monitoring our systems to check compliance, we generally do not access personal and private email information, provided they are marked as confidential.

• We do not process special personal data for equality and diversity purposes without your consent or will do so on an anonymous basis only.

• Background checks will be carried out only if strictly necessary in connection with the duties assigned and to the extent that this would be allowed under the applicable law.

Russia

If you are employed, engaged, or reside in Russia, the following additional information applies.

The local regulator is the Russian Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor).

Legal grounds for processing personal data

In most scenarios described in the “FURTHER INFORMATION ON THE PERSONAL DATA WE PROCESS AND OUR PURPOSES” section of this Notice we will request your explicit consent to the processing of your personal data for the respective purposes. Moreover, where we are required to do so by Russian law, we will request your consent. Grounds for the data processing described in said section of this Notice apply together with your consent and will further apply in case you revoke your consent.

Further information on the data we process and our purposes

Subject to certain statutory exceptions, we will not process personal data relating to your criminal convictions. In general, we will process your special personal data and biometric data only to an extent we need to do so as per Russian law and subject to your consent.

Who gets to see your data?

We will keep records of the third parties who may access your personal data or otherwise may be involved in its processing. If you want to learn more about such third parties, please contact us at EmployeePrivacy@viacomcbs.com.

Retaining your personal data

As per Russian tax, accounting, and archive laws, we are required to retain certain documents containing your personal data. For example, we may need to retain your personnel files and employment contracts for up to 50 years. We put in place all appropriate safeguards to ensure that such documents are retained in a secure manner and destroyed upon expiration of the prescribed statutory terms.

International transfers

Although we may transfer your personal data outside Russia, we will in any case make sure that we comply with applicable local requirements on the initial processing of your personal data in Russia (e.g. data localization requirements).

How we process your personal data

In most cases, we process your personal data with the use of automated means, however in some cases we also need to do so without such means (manually).

We may process your personal data by way of any operations to the extent required to fulfil our stated processing purposes. In particular, such operations may include collection, recording, systematization, accumulation, storage, specification (update, modification), retrieval, use, transfer (provision, access, dissemination), depersonalization, blockage, deletion, or destruction of personal data.

Singapore

If you are employed, engaged, or reside in Singapore, the following additional information applies.

The local regulator is the Personal Data Protection Commission (“the PDPC”).

The Personal Data Protection Act 2012 establishes a general data protection law in Singapore which governs the collection, use and disclosure of individuals’ personal data by organizations. “Organizations” include any company formed or recognized in Singapore or having an office or a place of business in Singapore.

South Africa

If you are employed, engaged, or reside in South Africa, the following additional information applies.

The local regulator is the Information Regulator.

Your rights under the laws of South Africa

If you are a resident of South Africa, you have certain additional rights under South African law:

• The right to be notified that your personal data is being collected;

• The right to be notified that your personal data has been accessed or acquired by an unauthorized person;

• The right not to have your personal data processed for purposes of direct marketing by means of unsolicited electronic communications;

• The right not to be subject to a decision based solely on the automated processing of your personal data intended to provide a profile of you;

• The right to submit a complaint to the Information Regulator regarding the alleged interference with the protection of your personal data; and

• The right to institute civil proceedings regarding the alleged interference with the protection of your personal data.

In addition:

When processing personal data and special personal data for diversity and inclusion purposes, we will typically rely on the legal obligations imposed on us under the Employment Equity Act 55 of 1998 in respect of employment equity planning. Where, however, certain personal data is not legally required (for example sexual orientation or LGBTQ status), this personal data will be processed on the basis of specific and explicit consent.

Spain

If you are employed, engaged, or reside in Spain, the following additional information applies.

The local regulator is the Spanish Data Protection Authority (www.aepd.es).

In addition:

We will generally not process health data and will only receive limited information – i.e. whether an employee is fit for the job from a health perspective. Notwithstanding this, as stated in the Notice, personal data may be collected as necessary to maintain the safety and health of employees in relation to COVID 19 or other pandemics..

Sweden

If you are employed, engaged, or reside in Sweden, the following additional information applies.

The local regulator is Integritetsskyddsmyndigheten.

In addition:

We will not process special personal data for diversity and equal opportunities purposes or will do so on an anonymous basis only.

Switzerland

If you are employed, engaged, or reside in Switzerland, the following additional information applies.

The local regulator is the Federal Data Protection and Information Commissioner.

In addition:

• When collecting special personal data, criminal data, or personality profiles, we will inform you in advance of the data collection purpose and of any data recipient and will ask you for your consent.

• Your activity on the company’s intranet, internet, access logs, web history and searches, as well as access and usage of emails and documents, will be monitored in line with the Swiss Data Protection Act.

• We will only gather references from former employers with your prior consent.

United Kingdom

If you are employed, engaged, or reside in the United Kingdom, the following additional information applies.

The local regulator is the Information Commissioner’s Office (ICO).

In addition:

• When processing special personal data for diversity and inclusion purposes we will typically rely on Schedule 1(8) Data Protection Act 2018 as the legal basis for processing, rather than consent. However, in practice this sort of processing would normally still be voluntary.

• This Notice, along with other related Paramount policies and/or protocols, shall form Paramount's policy for processing special personal data as required by the UK Data Protection Act 2018 (Schedule 1 Part IV).

1. For the purposes of this Notice, “Paramount”, “we”, “us” and “our” refer to (i) Paramount Inc., (ii) for U.S. based employees, the Paramount subsidiary that employs you or to which you provide services, and/or, (iii) for employees based outside the U.S., the local Data Controller(s) set out in the International Supplements, and other group companies with whom the data is shared (as outlined in this Notice).