LEGAL

APPLICANT & EMPLOYEE PRIVACY NOTICE

Effective Date: July 1, 2026 | Last Updated: July 9, 2026

Privacy PolicyApplicant and Employee

Table of contents

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1. PURPOSE

This Applicant & Employee Privacy Notice ("Notice") explains how The Halal Shack Inc. and its Family of Brands ("Company," "we," "our," or "us") collects, uses, discloses, stores, retains, and otherwise processes Personal Information relating to applicants, employees, former employees, interns, temporary employees, seasonal employees, independent contractors, consultants, officers, directors, and other members of our workforce.

This Notice supplements the Company's General Privacy Policy. To the extent this Notice conflicts with the General Privacy Policy regarding employment-related information, this Notice shall govern.

The Company is committed to protecting the privacy of workforce members while collecting and processing Personal Information necessary to recruit, employ, compensate, develop, support, and manage our workforce in accordance with applicable law.

2. SCOPE

This Notice applies to Personal Information collected in connection with:

  • Employment applications;
  • Recruiting activities;
  • Interviews;
  • Hiring decisions;
  • Background screening (where permitted by law);
  • Onboarding;
  • Payroll administration;
  • Benefits administration;
  • Workforce scheduling;
  • Timekeeping;
  • Training;
  • Performance management;
  • Workplace investigations;
  • Travel and expense administration;
  • Safety and security;
  • Compliance with legal obligations;
  • Separation from employment; and
  • Other employment-related business activities.

This Notice applies to:

  • Applicants;
  • Current employees;
  • Former employees;
  • Seasonal employees;
  • Temporary employees;
  • Interns;
  • Independent contractors (where applicable);
  • Consultants;
  • Officers and directors; and
  • Individuals whose information is collected during the recruiting process.

This Notice does not create contractual rights, modify any employment relationship, or alter the at-will employment status of any employee unless otherwise provided by written agreement or applicable law.

3. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Depending on your relationship with the Company, we may collect the following categories of Personal Information.

A. Personal Identifiers

  • Full legal name;
  • Preferred name;
  • Home address;
  • Mailing address;
  • Telephone number;
  • Email address;
  • Date of birth;
  • Employee identification numbers;
  • Government-issued identification numbers where required by law;
  • Emergency contact information.

B. Employment Information

The Company may collect information relating to:

  • Employment applications;
  • Résumés and curriculum vitae;
  • Employment history;
  • Professional references;
  • Educational history;
  • Licenses and certifications;
  • Interview notes;
  • Hiring documentation;
  • Offer letters;
  • Employment agreements;
  • Job titles;
  • Department assignments;
  • Reporting relationships;
  • Work location;
  • Employment status;
  • Scheduling information;
  • Attendance records;
  • Timekeeping records;
  • Performance evaluations;
  • Coaching documentation;
  • Corrective action documentation;
  • Training records;
  • Internal promotions;
  • Transfers;
  • Separation information;
  • Exit interviews; and
  • Other employment-related records.

C. Payroll and Benefits Information

Where applicable, the Company may collect information necessary to administer compensation and benefits, including:

  • Payroll information;
  • Tax withholding documentation;
  • Direct deposit information;
  • Compensation history;
  • Wage and salary information;
  • Bonus eligibility;
  • Incentive compensation;
  • Benefits enrollment;
  • Retirement plan participation;
  • Leave administration;
  • Workers' compensation information;
  • Expense reimbursement information; and
  • Other information reasonably necessary for payroll or benefits administration.

D. Professional Qualifications

The Company may collect:

  • Education records;
  • Professional certifications;
  • Training history;
  • Professional licenses;
  • Skills assessments;
  • Interview evaluations;
  • Work samples;
  • Language proficiency;
  • Eligibility to work;
  • Position qualifications;
  • Internal certifications; and
  • Continuing education records.

E. Communications

The Company may collect information contained within business communications, including:

  • Emails;
  • Telephone communications;
  • Text messages;
  • Video conference communications;
  • Internal messaging platforms;
  • Meeting invitations;
  • Calendar information;
  • Meeting recordings;
  • Meeting transcripts;
  • Administrative notes;
  • Customer communications involving employees;
  • Recruiting communications; and
  • Other communications conducted using Company systems or in connection with Company business.

F. Technology and Device Information

When Company technology or systems are used, the Company may collect information such as:

  • Login activity;
  • Device identifiers;
  • IP addresses;
  • Browser information;
  • Operating system information;
  • Network logs;
  • Authentication information;
  • System access records;
  • Security logs;
  • Usage information; and
  • Other information necessary for security, troubleshooting, or administration.

Collection of such information is limited to legitimate business, operational, compliance, and security purposes.

G. Security Information

Where appropriate and permitted by law, the Company may collect information relating to:

  • Building access;
  • Visitor logs;
  • Security incidents;
  • Workplace investigations;
  • Safety reports;
  • Incident reports;
  • Fraud prevention;
  • Policy compliance; and
  • Other information reasonably necessary to maintain a safe, secure, and compliant workplace.

H. Information We Generally Do Not Collect

Except where required by law or voluntarily provided by you, the Company does not intentionally collect Personal Information unrelated to legitimate employment or business purposes.

The Company does not intentionally collect Sensitive Personal Information for purposes unrelated to employment administration, payroll, benefits, legal compliance, workplace safety, or other lawful business activities.

Where collection of certain categories of Sensitive Personal Information is required by law, such information will be collected only as reasonably necessary and handled in accordance with applicable legal requirements.

4. SOURCES OF PERSONAL INFORMATION

The Company may collect Personal Information from a variety of sources, including:

  • Directly from applicants and employees;
  • Through employment applications and recruiting activities;
  • During interviews;
  • Through onboarding documentation;
  • Through payroll and human resources administration systems;
  • Through applicant tracking systems and recruiting platforms;
  • Through scheduling and workforce management systems;
  • Through benefits administrators;
  • Through background screening providers, where permitted by law;
  • From references identified by applicants;
  • From educational institutions or professional licensing authorities, where authorized or required by law;
  • Through Company-issued devices or systems;
  • Through business communications;
  • From government agencies where required or authorized by law;
  • From publicly available sources where permitted by law; and
  • From other lawful sources consistent with applicable law.

Data Minimization and Accuracy

The Company seeks to collect only the employment-related Personal Information reasonably necessary for legitimate business purposes. Applicants and employees are encouraged to promptly notify the Company of changes to their Personal Information so Company records remain accurate.

The Company may combine information obtained from multiple lawful sources to administer employment, improve business operations, comply with legal obligations, and protect Company interests.

Applicability of State Privacy Laws

The Company operates in multiple jurisdictions throughout the United States and is committed to complying with applicable federal, state, and local privacy laws.

Certain state comprehensive privacy laws apply to consumers and may exclude or limit their application to Personal Information collected in the context of an individual's role as a job applicant, employee, owner, director, officer, contractor, or other workforce member. Other states may extend certain privacy rights to employment-related Personal Information.

Where an applicable state law provides privacy rights relating to employment or applicant information, the Company will honor those rights in accordance with applicable law.

Where employment-related information is exempt from a particular state privacy law, the Company will continue to collect, use, retain, disclose, and safeguard such information in accordance with applicable employment, labor, payroll, tax, benefits, recordkeeping, and other legal requirements.

The Company continuously monitors changes in applicable privacy laws and may update this Notice as necessary to reflect changes in legal requirements or business operations.

5. HOW WE USE PERSONAL INFORMATION

The Company processes Personal Information solely for legitimate business, employment, operational, legal, and compliance purposes. Depending upon your relationship with the Company, your Personal Information may be used to:

A. Recruiting and Hiring

The Company may use Personal Information to:

  • Review employment applications;
  • Evaluate qualifications for employment;
  • Schedule interviews;
  • Communicate with applicants;
  • Verify employment history and qualifications;
  • Conduct lawful background checks and employment eligibility verification where permitted by law;
  • Assess an applicant's qualifications for available positions;
  • Extend employment offers;
  • Maintain recruiting records;
  • Improve recruiting processes; and
  • Comply with applicable employment laws.

The Company may retain applicant information for future employment opportunities where permitted by applicable law unless an applicant requests otherwise.

B. Employment Administration

The Company may use Personal Information to administer the employment relationship, including:

  • Onboarding;
  • Payroll administration;
  • Workforce scheduling;
  • Timekeeping;
  • Benefits administration;
  • Tax reporting;
  • Performance management;
  • Training and professional development;
  • Leave administration;
  • Internal reporting;
  • Workforce planning;
  • Promotions;
  • Transfers;
  • Compensation administration;
  • Expense reimbursement;
  • Separation administration; and
  • Other legitimate employment-related purposes.

C. Legal Compliance

The Company may process Personal Information to:

  • Comply with federal, state, and local laws;
  • Respond to governmental agencies;
  • Maintain employment records;
  • Satisfy tax obligations;
  • Comply with wage and hour laws;
  • Administer workplace safety requirements;
  • Maintain legally required records;
  • Respond to lawful requests;
  • Exercise or defend legal claims; and
  • Fulfill other legal obligations.

D. Security and Business Operations

The Company may use Personal Information to:

  • Protect Company property;
  • Protect confidential business information;
  • Prevent fraud;
  • Investigate policy violations;
  • Investigate workplace complaints;
  • Maintain information security;
  • Protect employees and applicants;
  • Conduct internal audits;
  • Improve operational efficiency;
  • Maintain business continuity; and
  • Support legitimate business operations.

6. ARTIFICIAL INTELLIGENCE ("AI") AND AUTOMATED TECHNOLOGIES

The Company may utilize artificial intelligence ("AI"), machine learning, automation, natural language processing, and similar technologies provided by trusted third-party Service Providers to support recruiting, employment administration, and other legitimate business functions.

These technologies may assist with:

  • Scheduling interviews;
  • Coordinating applicant communications;
  • Organizing employment applications;
  • Resume parsing and document organization;
  • Interview transcription;
  • Meeting summaries;
  • Administrative note taking;
  • Calendar management;
  • Workflow automation;
  • Document management;
  • Reporting;
  • Compliance administration;
  • Internal operational efficiency; and
  • Other administrative functions.

AI technologies are used solely as administrative and decision-support tools. The Company does not make hiring, promotion, compensation, disciplinary, termination, or other employment decisions based solely upon automated processing. All employment decisions are reviewed and made by qualified Company personnel using human judgment and in accordance with Company policies and applicable law.

Use of Public Artificial Intelligence Platforms

The Company does not intentionally submit confidential Company information, applicant information, employee Personal Information, trade secrets, payroll information, or other sensitive information into publicly available generative artificial intelligence platforms except through approved Company processes, approved Service Providers, or as otherwise authorized under Company policy.

The Company does not rely exclusively on artificial intelligence or automated processing to make decisions regarding hiring, promotion, discipline, compensation, scheduling, termination, or any other employment action that produces legal or similarly significant effects unless expressly permitted by applicable law.

The Company may implement additional AI-enabled technologies in the future to improve operational efficiency, provided such technologies are used in accordance with applicable law and this Notice.

7. MEETING RECORDINGS, TRANSCRIPTION, AND BUSINESS COMMUNICATIONS

To facilitate collaboration, documentation, training, operational efficiency, and business continuity, the Company may utilize communication and collaboration technologies that include recording, transcription, note generation, or meeting summarization capabilities.

Where recording or transcription is enabled, participants will generally receive notice through the applicable platform or other appropriate means.

The Company may also monitor, access, review, retain, or disclose information created, transmitted, received, or stored using Company-owned or Company-authorized email accounts, collaboration platforms, devices, networks, internet access, building access systems, badge systems, and other business technologies for legitimate business purposes, consistent with applicable law.

Meeting recordings, transcripts, summaries, and administrative notes may be used for legitimate business purposes, including:

  • Documentation;
  • Training;
  • Operational planning;
  • Compliance;
  • Project management;
  • Internal communications;
  • Recordkeeping; and
  • Business continuity.

The Company does not use meeting transcription technologies to create behavioral profiles, biometric identifiers, or employment decisions based solely on automated analysis.

8. BACKGROUND CHECKS, EMPLOYMENT VERIFICATION, AND REFERENCES

Where permitted by applicable law and appropriate for the position, the Company may obtain information from authorized third parties regarding:

  • Criminal history;
  • Employment verification;
  • Education verification;
  • Professional licenses;
  • Professional references;
  • Identity verification;
  • Work authorization;
  • Driving records, where job-related; and
  • Other information reasonably necessary for employment.

Background screening will be conducted only in accordance with applicable federal, state, and local law, including the Fair Credit Reporting Act ("FCRA") and any applicable state or local fair chance or background screening laws.

9. WORKPLACE INVESTIGATIONS AND COMPLIANCE

The Company may process Personal Information when reasonably necessary to:

  • Investigate workplace concerns;
  • Respond to employee complaints;
  • Investigate policy violations;
  • Conduct internal audits;
  • Maintain workplace safety;
  • Prevent fraud;
  • Protect Company assets;
  • Comply with legal obligations;
  • Cooperate with governmental investigations;
  • Respond to litigation;
  • Preserve evidence; and
  • Protect the rights of the Company and others.

Information collected during workplace investigations will be accessed only by individuals with a legitimate business need and handled in accordance with applicable law.

10. WHO WE SHARE EMPLOYMENT INFORMATION WITH

The Company may disclose employment-related Personal Information only where reasonably necessary and consistent with applicable law.

Depending upon business needs, information may be shared with:

  • Payroll providers;
  • Benefits administrators;
  • Applicant tracking system providers;
  • Human resources information system providers;
  • Workforce management and scheduling providers;
  • Background screening providers;
  • Employment verification providers;
  • Information technology providers;
  • Cloud hosting providers;
  • Professional advisors;
  • Attorneys;
  • Accountants;
  • Auditors;
  • Insurance providers;
  • Government agencies;
  • Regulatory authorities;
  • Financial institutions;
  • Business partners providing services on behalf of the Company; and
  • Other Service Providers reasonably necessary to administer employment or business operations.

The Company does not sell employee or applicant Personal Information for monetary consideration.

The Company performs commercially reasonable due diligence when selecting Service Providers and seeks to require appropriate contractual, technical, administrative, and organizational safeguards designed to protect Personal Information. Service Providers are contractually required to process Personal Information only for authorized business purposes.

11. DATA RETENTION

The Company retains applicant and employee Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Notice, satisfy legitimate business needs, comply with applicable law, resolve disputes, enforce Company policies and agreements, or defend against actual or potential legal claims.

Retention periods vary depending upon the type of information collected, the individual's relationship with the Company, operational needs, and applicable legal requirements.

Examples include, but are not limited to:

  • Recruiting records;
  • Employment applications;
  • Payroll records;
  • Benefits records;
  • Tax documentation;
  • Scheduling and timekeeping records;
  • Training records;
  • Performance documentation;
  • Workplace investigation records;
  • Separation records;
  • Communications;
  • Meeting recordings or transcripts, where applicable;
  • Compliance documentation; and
  • Other employment-related records.

When Personal Information is no longer required, the Company will securely delete, destroy, anonymize, or de-identify such information in accordance with its record retention practices and applicable law.

The Company may suspend ordinary deletion practices when information becomes subject to litigation holds, government investigations, audits, subpoenas, or other legal preservation requirements.

Where required by law, litigation hold, government investigation, audit, or other legal obligation, the Company may retain information for longer periods.

12. INFORMATION SECURITY

The Company maintains administrative, technical, organizational, and physical safeguards designed to protect Personal Information from unauthorized access, disclosure, alteration, misuse, destruction, or loss.

Security measures may include, where appropriate:

  • Role-based access controls;
  • Multi-factor authentication;
  • Password management;
  • Encryption where appropriate;
  • Secure cloud environments;
  • Security monitoring;
  • Vendor due diligence;
  • Access logging;
  • Employee training;
  • Incident response procedures;
  • Confidentiality agreements; and
  • Other commercially reasonable safeguards.

Access to Personal Information is limited to individuals who require such access for legitimate business purposes.

Although the Company employs commercially reasonable safeguards, no method of storing, transmitting, or processing information can be guaranteed to be completely secure.

Security Incidents

If the Company becomes aware of a suspected or confirmed security incident involving employment-related Personal Information, the Company will investigate the incident, take commercially reasonable measures to mitigate potential harm, and provide any notifications required by applicable law.

Accordingly, to the fullest extent permitted by applicable law, the Company disclaims any representation or warranty regarding absolute security and shall not be liable for unauthorized access, disclosure, alteration, destruction, cyberattacks, or security incidents beyond the Company's reasonable control.

Nothing contained in this Notice shall be interpreted as creating a contractual guarantee regarding information security.

13. EMPLOYEE AND APPLICANT PRIVACY RIGHTS

Depending upon applicable federal, state, or local law, applicants and employees may have certain privacy rights relating to their Personal Information.

Subject to applicable legal limitations, these rights may include:

  • The right to request access to certain Personal Information;
  • The right to request correction of inaccurate Personal Information;
  • The right to request deletion of certain Personal Information where permitted by law;
  • The right to receive information regarding categories of Personal Information collected;
  • The right to receive information regarding categories of disclosures made by the Company;
  • The right to exercise applicable rights without unlawful retaliation or discrimination; and
  • Any additional rights provided under applicable law.

Certain information may not be deleted or modified where retention is required for payroll administration, tax reporting, employment records, legal compliance, litigation, workplace investigations, or other lawful business purposes.

Additional rights applicable to residents of certain states are described in the Company's applicable U.S. State Privacy Notice, which is incorporated into this Notice by reference.

14. CONFIDENTIALITY EXPECTATIONS

Applicants and employees may receive access to confidential, proprietary, trade secret, financial, operational, personnel, customer, vendor, or other sensitive Company information during the course of their relationship with the Company.

Nothing in this Notice modifies any confidentiality, non-disclosure, intellectual property, restrictive covenant, or other legal obligations owed to the Company.

Employees are expected to protect confidential Company information in accordance with Company policy and applicable agreements.

Nothing in this Notice is intended to interfere with or restrict rights protected under applicable labor or employment laws, including protected concerted activity.

15. CHANGES TO THIS NOTICE

The Company reserves the right to revise, modify, supplement, or replace this Notice at any time to reflect:

  • Changes in applicable law;
  • Business operations;
  • Employment practices;
  • Technology;
  • Artificial intelligence capabilities;
  • Service Providers;
  • Security practices;
  • Regulatory guidance; or
  • Other legitimate business needs.

Material revisions will become effective upon publication or other notice provided by the Company, where required by applicable law.

This Notice becomes effective on the Effective Date identified above. The Company may update this Notice from time to time as permitted by applicable law. Nothing in this Notice diminishes any rights provided under applicable law.

16. NO CONTRACTUAL RIGHTS

This Notice is provided for informational and transparency purposes only.

Nothing contained in this Notice shall:

  • Create a contract of employment;
  • Alter the at-will employment relationship (where applicable);
  • Create contractual privacy rights beyond those required by applicable law;
  • Limit the Company's legal rights;
  • Limit the Company's management rights; or
  • Restrict the Company's ability to administer employment or business operations in accordance with applicable law.

17. CONTACT INFORMATION

Questions regarding this Notice or the Company's privacy practices may be directed to:

The Halal Shack Inc.
Privacy Officer
94 Hubbs Rd, Ballston Lake NY 12019
Email: info@thehalalshack.com
Telephone: 518-779-2829
Website: www.thehalalshack.com

The Company will make reasonable efforts to respond to privacy-related inquiries in accordance with applicable law.

18. INCORPORATION OF OTHER COMPANY POLICIES

Reservation of Rights

The Company reserves the right to modify its recruiting practices, employment administration systems, Service Providers, artificial intelligence technologies, security controls, retention schedules, operational processes, and privacy practices as permitted by applicable law.

This Notice should be read together with the Company's:

  • General Privacy Policy;
  • U.S. State Privacy Notice;
  • Information Security Policy;
  • Acceptable Use Policy;
  • Employee Handbook;
  • Records Retention Policy;
  • Artificial Intelligence Policy (if adopted);
  • Information Technology Policies; and
  • Other applicable Company policies and procedures.

In the event of a conflict between this Notice and applicable law, applicable law shall control.

19. GOVERNING LAW AND SEVERABILITY

This Notice shall be interpreted in accordance with applicable federal, state, and local law.

If any provision of this Notice is determined to be unlawful, invalid, or unenforceable, the remaining provisions shall remain in full force and effect to the fullest extent permitted by law.

ACKNOWLEDGMENT

Applicants and employees may be asked to acknowledge receipt of this Notice electronically or in writing. Acknowledgment confirms receipt of the Notice and does not constitute a waiver of any rights provided under applicable law.