Effective Date: January 1, 2023

Employee, Contractor, and Applicant Privacy Notice

This Employee, Contractor, and Applicant Privacy Notice (this “Notice”) explains how GoodRx and its affiliates (collectively, “GoodRx, “we,” “us,” or “our”) processes personal information about our California-based employees, contractors, and job applicants (collectively, “personnel” or “you” or “your”) and their family members or other individuals about whom we process personal information as a result of the relationships those individuals have with such personnel.

For purposes of this Notice, “personal information” has the meaning given in the CCPA. It does not include, and this Notice does not cover, information that is deidentified or aggregated such that it cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

This Notice applies to GoodRx’s processing of your personal information as an employee, contractor, or job applicant and does not cover your use of GoodRx’s products and services as a consumer or outside of your regular employment or of the job application process.

If you use the GoodRx website and services, please see the GoodRx privacy policy (goodrx.com/privacy-policy) for additional information.

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Categories of Personal Information: For each category of personal information, the list of examples is intended to be illustrative and not exhaustive. In connection with an individual’s role as a member of our personnel, we may not collect every example listed within a category nor use every example for each business purpose identified within each category. 

In addition to the business purposes set forth above, we may use these categories of personal information:

• To fulfill or meet the reason you provided the personal information;
• To comply with our health, safety, compliance, and fraud-prevention obligations;
• To create anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes;
• To authorize, grant, administer, monitor, and terminate access to or use of company systems, facilities, records, property, and infrastructure
• To manage business travel (e.g., car service/rentals, flights, hotels) and personnel expenses (e.g., reimbursement, corporate credit card).
• To facilitate personnel compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, insurance); 
• To establish, exercise, or defend legal claims;
• To comply with applicable law, court orders, subpoenas, and governmental regulations or investigations;
• To respond to requests by public authorities, including for the purpose of meeting national security or law enforcement requirements;
• In the event of a merger, acquisition, disposition of all or substantially all of the relevant assets of the business, bankruptcy, or similar event (including due diligence related thereto); 
• As described to you when collecting your personal information; or
• As otherwise authorized or required by applicable law.

Disclosure of Personal Information: We may share your personal information with other parties as necessary for the purposes described above. For example, we may disclose your personal information with:

• Affiliates. Our subsidiaries, and other affiliates for purposes consistent with this Notice or to operate shared infrastructure, systems, and technology.
• Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), recruitment analytics, benefit administrators, compensation, payroll, and tax providers.
• Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
• Business transfers. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
• Customers and business partners. Customers, other companies, and individuals with whom the Company does business or is exploring a business relationship.

We do not sell any information regarding employment-related personal information to third parties for monetary or other valuable consideration. However, as stated above, in the event of a merger to, acquisition by, or similar event relating to a third party, we may transfer your personal information to the new owners/entities pursuant to such event.

Retention of Personal Information: We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

Relatedly, we may retain application information for unsuccessful applicants beyond consideration of the immediate position for which the application is submitted as a reference in case future positions become available and are of interest. Application information for successful applicants becomes part of the applicant’s employment file and is treated accordingly. 

Sensitive Information: The following personal information elements, which are also identified above, may be classified as “sensitive” under the CCPA (“sensitive information”): Social Security number, work-related accounts and passwords, and financial account information. We may use this sensitive information for the purposes set forth regarding personal information.

Your Rights Under the CCPA & CPRA: Subject to certain exceptions, California residents can exercise their right to know, correct, and delete personal information subject to the limitations of the California Consumer Privacy Rights Act of 2018, as amended by the California Privacy Rights Act. If you are a California resident, you can submit a GoodRx Employee Data Deletion Request form for the right to delete and the GoodRx Employee Data Access Request form for the right to know. You may also contact us at datarequest@goodrx.com. 

If you have any questions, please contact legal@goodrx.com.

Submitting Authorized Agent Requests: In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request

Changes to this Notice: We reserve the right to change this Notice at any time. The “Effective Date” heading at the top of this Notice indicates when it was last revised. Any changes will become effective when we post the revised notice on our Careers Site.