NOTICE TO SPROTT JOB APPLICANTS RESIDENT IN CALIFORNIA

This California Job Applicant Privacy Notice is effective as of January 1, 2023.

This notice supplements Sprott’s Privacy Policy and applies only to job applicants that are residents of California (“California Applicant”).  This California Job Applicant Privacy Notice sets forth the disclosures and rights for California Applicants regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Personnel Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.   

EXERCISING YOUR CALIFORNIA RIGHTS

California Applicants have the right to request:

1. that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you ("Right to Know");
   1. To exercise your Right to Know, please submit your request by contacting our Privacy Officer by telephone at 855.943.8099, by e-mail at privacy@sprott.com or by mail to Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada, Attention: Privacy Officer.
   2. In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California Applicant whose Personal Information is the subject of the request. We will not provide you specific pieces of information that include the Personal Information of other persons, nor will we disclose certain pieces of information that the law requires us not to or that we determine is a high security risk, including your social security number, driver’s license number, financial account number, health insurance or medical information number, account passwords, security questions and answers, or unique biometric data, as applicable.
2. that we delete the Personal Information we collect from you ("Right to Delete");
   1. To exercise your Right to Delete, please submit your request by contacting our Privacy Officer by telephone at 855.943.8099, by e-mail at privacy@sprott.com or by mail to Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada, Attention: Privacy Officer.
   2. Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.
3. that we correct inaccurate Personal Information we hold about you (“Right to Correct”);
   1. If you would like to exercise your Right to Correct, please submit your request by contacting our Privacy Officer by telephone at 855.943.8099, by e-mail at privacy@sprott.com or by mail to Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada, Attention: Privacy Officer.
4. to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”);
   1. Sprott does not share your Sensitive Information with third parties for cross-context behavioral advertising.
5. to opt-out from the sale of your Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”);
   1. Sprott does not sell Personal Information.
6. that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.
   1. Sprott does not sell, or share for cross-context behavioral advertising, the Personal Information or Sensitive Personal Information collected from applicants.
   2. As disclosed in the chart below, we may collect certain information in connection with your recruitment with us that is considered Sensitive Personal Information under California law. Sprott does not request Sensitive Personal Information in connection with recruiting unless permitted or required by local law (for example for equal opportunity monitoring or internal policies related to diversity and anti-discrimination). Where required by applicable data protection or privacy law, we will obtain your consent to our use of your sensitive personal information.
   3. Sprott’s use and disclosure of Sensitive Personal Information collected during recruitment falls within this list of exceptions and we therefore do not offer such opt-out right at this time.

Verifying Your Requests

When you exercise your rights we will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may need to ask you to provide us with additional information to verify your identity and fulfill your request. We will only use any such information to verify your identity. If we cannot verify your identity, we will not be able to process the request.

Pursuant to the CPRA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sharing, Right to Opt-Out of Sale, or Right to Limit the Use and Disclosure of Sensitive Personal Information.

Authorized Agents

You may elect to use an agent to submit a request on your behalf. If you choose to do so, your agent must follow the instructions below to make the request. When your authorized agent submits a request on your behalf, we will request written permission signed by you and authorizing your agent to make the request on your behalf. The written permission must state your full legal name as the subject of the request, the full legal name of the individual who is acting as your agent and must be clear about the scope of permission granted. Alternatively, your agent may, but is not required to, submit a copy of a power of attorney under Probate Code sections 4000-4465.  In either case, your agent should also indicate in their email the nature of the request. Your identity, in addition to your agent’s identity and authorization, will need to be independently verified in order for us to be able to fulfill the request.  We may also ask you to directly confirm with us that you provided your agent permission to submit a request. Please keep in mind that if we do not receive adequate proof that your agent is authorized to act on your behalf, we will deny the request.

Data Retention

Sprott retains your personal information until the end of your employment plus 7 years and any additional time periods necessary for compliance with law, exercise or defense of legal rights, and archiving, back-up and deletion processes.

For more information please contact privacy@sprott.com. If you have a visual disability, please contact careers@sprott.com for accommodations.

Personnel Younger than 18

We do not knowingly collect or sell Personal Information of employees or other personnel younger than 18 years of age.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

California Applicants have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate or retaliate against you for exercising your CCPA and CPRA rights.

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon the information you submitted during the recruitment process as well as how you otherwise interact with us. Accordingly, we may not collect all the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA

Personal Information Not Related to Employment

We may collect Personal Information from you when you make purchases from Sprott in your individual capacity and outside the context of your application for employment with us. Personal Information we collect from you during these transactions is not subject to this California Personnel Privacy Notice. We will collect, use, store, disclose, and/or otherwise handle Personal Information collected outside the context of your employment as we describe in our consumer privacy policy, found at https://www.sprott.com/ccpa-disclosures. If you wish to make a California consumer request in connection with such Personal Information, you must do so using the methods shown in the California privacy notice to consumers also found at https://www.sprott.com/ccpa-disclosures.

Questions about this Policy

Any questions regarding this Policy may be directed to Our Privacy Officer by telephone at 855.943.8099, by e-mail at privacy@sprott.com or by mail to Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada, Attention: Privacy Officer.