Effective date: July 9, 2025

1. Overview

This Employee and Contractor Privacy Policy (the “Privacy Policy”) contains the policies and procedures to be followed by Clearfield, Inc. and its subsidiaries, including its present or future subsidiaries (the “Company,” “Clearfield,” “we,” “us,” or “our”) related to the collection and use of personal information of an applicant, an employee (“Employee”), a Company officer or director, or a contractor in the United States (collectively referred to in this Privacy Policy as the “Employee/Contractor,” “you,” or “your”). Note: A “Contractor” is a non-employee who performs services for Clearfield and is not employed by the Company. Certain sections of this privacy policy do not apply to Contractors.

Clearfield wants you to understand how and why we collect “Personal Information,” which includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Employee/Contractor.

Clearfield is committed to protecting the privacy of all of our Employees/Contractors, and we take administrative, technical, and physical safeguards to protect your Personal Information from unauthorized access, misuse, accidental loss, or alteration. However, Employees/Contractors should have no expectation of privacy when using technology provided by Clearfield or whenever accessing Clearfield technology resources or information.

If you are a resident of California, please see the California Privacy Notice Addendum for a full list of the disclosures and rights available to you under California law.

2. Notice of Employee Monitoring

We may monitor telephonic and electronic conversations or transmissions, including e-mail and internet access, by Employees/Contractors conducted using our systems or devices. This includes use of systems, computers, telephones, and other devices provided or maintained by the Company or by our service providers. We may monitor these devices and services to ensure their safety, security, and efficiency, to confirm compliance with our policies and procedures, and to permit internal evaluations.

3. What Information Do We Collect?

The following chart explains the categories of Personal Information that we may collect or process and the specific reasons for which we process each category of information. For more detailed information regarding why we process each category of information, please see the Purposes of Collection section, below.

Please note that we may not collect all categories of Personal Information about each Employee/Contractor. For example, if the collection of Personal Information relates to a specific benefit that is not generally available, we would only collect that Personal Information from the Employees/Contractors who are eligible for and enroll in the benefit. Additionally, when we collect a category of Personal Information, we may not collect each specific example listed.

4. Purposes of Collection

1. Administering the Employment/Contractor Relationship

We keep and process Personal Information for traditional employment and contractor engagement purposes. We use this information for management and administrative uses and only disclose it with others who have a need-to-know such information. We keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, while you are working for us, and after your employment or contract has ended. This includes using Personal Information to enable us to comply with any legal requirements associated with an employee or contractor relationship, to administer payroll, to provide you with benefits, ensure your safety, comply with an employment or service contract, and to demonstrate our commitment to equal employment opportunity and fair employment practices.

2. Compliance with Legal Obligations

In certain situations, we may need to collect and process your Personal Information to comply with our legal obligations. This may include:

• Tracking demographic information to confirm compliance with equal opportunity and non-discrimination policies and requirements;

• Processing information relating to your health, which could include reasons for absence and doctor’s reports and notes, in order to comply with our obligations under applicable employment and safety and health laws;

• Processing information regarding certifications and qualifications for your role or position;

• Processing information regarding participation in employment-related activities about which we are required to retain a record; and/or

• Processing information relevant to any alleged violations of the Company’s code of conduct (or comparable Company policy) or other Company policies necessary to investigate allegations and institute disciplinary action as is required.

3. Facilitate Communications and Efficiency

The Company uses various tools and platforms that allow Employees/Contractors to more easily communicate with each other and to more efficiently access and disclose various types of work product and schedules. Some tools may also allow Employees/Contractors to disclose information via social media or other channels, including information relating to job opportunities.

These tools and platforms may collect and disclose contact information and Company profile pictures; log certain preferences and actions; collect your geolocation; and create user profiles that allow Employees and the Company to track their efficiency and performance. We may also have access to communications sent using Company systems and devices.

4. Provide Benefits

We offer Employees a variety of benefits, including benefits related to healthcare, retirement savings, and the ability to order goods and services directly from the Company. We may also collect additional biometric and sensory information if you take advantage of other benefits that we may offer now or in the future, such as fitness-related benefits. When you participate in certain benefits programs, we may also generate a log of your activity, track internet and other network activity, and develop a user profile to provide those programs to you in a manner tailored to your preferences.

All benefits may not be available to all Employees, and the Company will only collect Personal Information to provide a benefit if the Employee is eligible for and enrolled in that benefit. Employees should take care to read the specific terms applicable to any particular mobile application or benefits program to understand the specific pieces of information collected.

5. Ensure the Safety of Employees, Contractors, Facilities, and Property

We collect various categories of information to ensure the safety of Employees/Contractors, facilities and property. This information helps verify the identity of Employees/Contractors in specific facilities and ensure the security of facilities and Company vehicles. Additionally, we may process certain categories of Personal Information to ensure the safety and security of our electronic systems and devices. This includes monitoring our systems for suspicious or fraudulent activity and other forms of illegal conduct. This monitoring is critical to ensure the safety and security of our systems and the confidential information that is entrusted to us.

5. Disposal of Personal Information

We take appropriate measures to ensure that your Personal Information is processed and disposed of in a manner that maintains its confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, are designed to ensure the complete destruction of Personal Information and eliminate the risk of subsequent unauthorized access or disclosure.

6. Updates to the Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the categories of information we collect or the reasons we collect that information, we will notify you by sending you an e-mail and/or by prominently posting notice of the changes. This Privacy Policy will also be posted to the HR portal on the Company’s SharePoint site. You can review or consult the Privacy Policy at any time.

The Company may be subject to certain laws and regulations relating to privacy and information security in more than one jurisdiction in which Employees/Contractors reside. If any term, covenant, condition, or provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid, void, or unenforceable, it is the intent of this Privacy Policy that the scope of the rights and obligations of the Privacy Policy be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Privacy Policy statement will in no way be affected, impaired, or invalidated as a result.

7. Contact Us with Questions

If you have questions regarding this Privacy Policy, please contact the Human Resources Department by e-mail at hr@seeclearfield.com, by telephone at (763) 265-4267, or by mail at 7050 Winnetka Ave. N., Minneapolis, MN 55428.

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California Privacy Notice Addendum

Effective Date: July 9, 2025

This California Privacy Notice Addendum (“California Addendum”) applies to applicants, employees, and contractors that are residents of the state of California. This California Addendum supplements our Employee and Contractor Privacy Policy (“Privacy Policy”). Words reused in this California Addendum shall be interpreted as defined by the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act, and implementing regulations (collectively, the “CCPA”).

This California Addendum will provide you with a summary of the categories of information we collect, the reasons that we collect each category of information, information regarding how we may disclose your Personal Information with third parties, and information regarding your rights under the CCPA.

1. Information We Collect and Sources of Personal Information

In the preceding 12 months, we have collected the categories of Personal Information identified above in the Employee and Contractor Privacy Policy. We collect the majority of the information directly from you, through the applications or forms you submit and the information you provide at the time of hiring. In addition to the information that you provide to us, we may collect information about you from third parties, such as information from third parties that provide accreditation, educational institutions, benefits providers, and vendors that provide background checks or related information. Finally, we may automatically collect, store, or otherwise process information about you as you use our tools, systems, or resources, or when you are on-site at one of our locations.

2. How Your Personal Information Is Disclosed

In the preceding 12 months, we have disclosed the following categories of employment related information with service providers, who are necessary for facilitating the employment relationship and providing you with benefits:

1. A (Identifiers), B (Personal), C (Classification), D (Commercial), F (Internet), I (Professional), J (Non-public education information), L (Sensitive).

Where necessary, we enter into written contracts with our service providers to ensure the privacy and security of your Personal Information. Under these contracts, we restrict the access to and processing of your Personal Information to that which is necessary for the purpose of the disclosure.

In certain circumstances, we may provide you with opportunities to sign up for certain benefits programs that involve the disclosure of your Personal Information to third party benefits providers. Any such program will be purely optional and based on your opt-in participation.

In the preceding 12 months, we have not shared or sold employment-related Personal Information to third parties as those terms are defined by the CCPA.

We do not collect, process, or disclose sensitive Personal Information, as defined under the CCPA, for purposes other than those specified in Section 7027 of the CCPA regulations.

3. Individual Rights

The CCPA provides residents of California with a series of rights regarding the processing of their Personal Information. This section explains the scope of these rights and outlines how you may exercise them.

1. Right to Know About Personal Information Collected, Disclosed, Shared, or Sold

You have the right to know whether we are processing your Personal Information and to request that we disclose the Personal Information we collect, use, and disclose to third parties. There are two types of Rights to Know requests that you can make: an Abbreviated Request and a Specific Information Request.

If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

1. Categories of Personal Information collected, sold, or shared;

2. Categories of sources from which Personal Information is collected;

3. Categories of third parties to whom the information is sold, shared or disclosed;

4. Business or commercial purpose for collecting, sharing, or selling Personal Information;

5. Categories of Personal Information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.

If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

1. Specific pieces of Personal Information collected about you.

We will provide this information to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

We will provide this information to you in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data without hindrance.

There are certain exceptions to the Right to Know. We will state in our response if an exception applies.

2. Right of Deletion

You have the right to request that we and our service providers delete Personal Information that we have collected about you by submitting a verifiable request. This right is subject to certain exceptions and does not require us to delete information that we are otherwise required to hold under applicable laws. We will state in our response if an exception applies.

3. Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your Personal Information by a business subject to certain laws and regulations. We do not sell or share information that we collect or process about you in your capacity as an Employee or Contractor.

To the extent you interact with the Company outside of your capacity as an Employee or Contractor, please see our general Privacy Policy.

4. Right of Correction

You have the right to request that we correct inaccuracies in any Personal Information that we collect or process about you upon receipt of a verifiable request. When submitting a correction request, we request that you provide all of the information reasonably necessary to confirm the accuracy of the correction request. This right is subject to certain exceptions. We will state in our response if an exception applies.

5. Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to request that we limit the use and disclosure of your Sensitive Personal Information to only those purposes specifically authorized under California law. At this time, we do not process or disclose your Sensitive Personal Information for purposes that are not specifically authorized under California law. Should this change, we will notify you and provide you with an opportunity to limit our processing of your Sensitive Personal Information.

6. Right to Non-Discrimination

We will not retaliate against any employee, applicant for employment, or independent contractor for exercising your rights under the CCPA. Additionally, we will not discriminate against you by: denying goods or services to you; charging different prices or rates for benefits, goods, or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Submitting Requests

To submit a rights request, you may email us at hr@seeclearfield.com or contact us by phone at (763) 265-4267.

We will provide responses to your requests free of charge unless exclusions apply, which we will identify in our response.

8. Verifying Requests

To ensure the protection of your Personal Information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the applicant, contractor, or employee to whom the request relates prior to processing the request. To verify your identity, we may request up to three pieces of Personal Information about you to compare against our records.

You will not be required to create an account with us to submit a verifiable request. However, you may be required to access an existing account to the extent accessing the account is necessary.

We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request, unless otherwise prohibited from doing so under applicable law. We reserve the right to take additional steps as necessary to verify your identity where we have reason to believe a request is fraudulent.

9. Authorized Agents

You may choose a person or business that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.

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GDPR Privacy Addendum

Last Updated: July 9, 2025

Residents of the European Union (“EU”), European Economic Area (“EEA”) member states, the United Kingdom (“UK”), and Switzerland have certain rights with respect to their data. These rights are established by the General Data Protection Regulation, the UK General Data Protection Regulation, and the Swiss Data Protection Act, (collectively the “GDPR”) This GDPR Privacy Addendum (“Addendum”) applies in circumstances where Clearfield, Inc.’s privacy practices are subject to the GDPR. This Addendum supplements and should be read in conjunction with the information in the Clearfield, Inc. Privacy Policy and applies solely to all users who access our services who are located in the EU, EEA, UK, or Switzerland. We adopt this Addendum to comply with the GDPR and any terms defined in the GDPR or our Privacy Policy have the same meaning when used in this Addendum. This Addendum takes precedence over anything contradictory in our Privacy Policy.

If you have any questions regarding this Addendum or the Clearfield, Inc. Privacy Policy, please contact us at hr@seeclearfield.com.

1. Legal Basis for Processing Personal Data

We will only process your personal data when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal data. The legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it, which is discussed below.

• Consent. We may process your personal data based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

  • Children’s Consent. We do not knowingly process data of EU, EEA, UK, or Switzerland residents under the age of 16 without reasonably verified parental consent.

• Our Legitimate Interests. We may process your personal data if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests. For example, our legitimate interests include but are not limited to when we process your personal data to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our products and services and the content and functionality of our products and services. Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.

• To Perform a Contract. We may process your personal data to administer and fulfill contractual obligations to you. We will also collect and process your personal data as necessary for the performance of a contract to which you are a party.

• To Enable Us to Comply With a Legal Obligation. We may process your personal data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.

• Necessary for the Exercise or Defense of Legal Claims. If you bring a claim against us or we bring a claim against you, we may process your personal data in relation to that claim.

Depending on the situation, we may be the controller or the processor for personal data collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data for any specific processing activity, please contact us using the “Contact Information” section below.

2. Transfers Abroad

Our services are operated in multiple countries, including the United States. Personal data you provide while in the EU, EEA, UK, or Switzerland may be transferred to the United States. The GDPR permits such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal data. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal data from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.

If you would like to receive further details of the measures that we have taken in this regard or for a copy of the safeguard(s), please contact us at hr@seeclearfield.com.

3. Your Rights

Under the GDPR, you are entitled by law to access, correct, amend, or delete personal data about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

If you wish to exercise any of the rights set out below, please contact us at hr@seeclearfield.com. For your protection, we may need to verify your identity before responding to a request. In the event that we refuse a request, we will provide you a reason as to why.

• Asking Us to Access Your Personal Data. You have the right to obtain from us confirmation as to whether or not we are processing personal data about you, and if so, the right to be provided with the information contained in this Addendum. You also have the right to ask us for copies of your personal data. When making a request, please provide an accurate description of the personal data that you want to access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost. If you have an account with us, you may be able to access your personal data directly within your account settings section or you may contact us to assist you using the information in the “Contact Information” section below.

• Asking Us to Rectify Your Personal Data. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. If you have an account with us, you may be able to enact these updates in your account or you can request these changes by using the information in the “Contact Information” section below.

• Asking Us to Delete Your Personal Data. You have the right to ask us to erase your personal data if:

  • We no longer need it for the purposes for which we collected it;

  • We have been using it with no valid legal basis;

  • We are obligated to erase it to comply with a legal obligation to which we are subject;

  • We need your consent to use the information and you withdraw consent; or

  • You object to us processing your personal data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with our Privacy Policy.

If you do exercise a valid right to have your personal data deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

• Asking Us to Restrict Our Use of Your Personal Data. You have the right to ask us to place a restriction on our use of your personal data if one of the following applies to you:

  • You contest the accuracy of the information that we hold about you, while we verify its accuracy;

  • We have used your information unlawfully, but you request us to restrict its use instead of erasing it;

  • We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or

  • You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

• The Right to Transfer Your Personal Data to Another Service Provider. You have the right to ask that we transfer the personal data you gave us from one organization to another, or give it to you (i.e., data portability). This applies to personal data we are processing to service a contract with you and to personal data we are processing based on your consent.

• The Right to Withdraw Consent. If we obtain your written consent to collect and process your personal data, you can subsequently withdraw such consent as to any further processing of such information.

• The Right to Lodge a Complaint with a Supervisory Authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).

• Rights Related to Automated Decision-Making. To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

• Right to Object to Processing. You have the right to object to the processing of your personal data that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal data by contacting us using the information in the “Contact Information” section below.

4. Changes to our Privacy Policy and this Addendum

We will only use personal data in the manner described in the Privacy Policy and this Addendum in effect when the information was collected from you. From time to time, we may change this Addendum. We will notify you of any changes by posting the new Addendum here or providing you with a copy of the new Addendum. If a change is material, we will provide at least thirty (30) days’ notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

Where required by the GDPR, you will be given the choice at that time to “opt-in” for any additional uses or disclosures of your personal data that you made available to us prior to the change in the Privacy Policy or this Addendum. In such circumstances, if you do not grant us your informed consent for the processing of your personal data for such additional purposes your personal data will not be used for any purposes other than those to which you have agreed.

5. Contact Information

E-Mail: hr@seeclearfield.com

Telephone: +1-763-265-4267

Address:
Clearfield, Inc.
c/o Human Resources Department
7050 Winnetka Ave N,
Minneapolis, MN 55428, U.S.A.