AEG Independent Contractor Privacy Policy

INTRODUCTION

Last Revised/Effective Date: 9/29/2025

Anschutz Entertainment Group, Inc., on behalf of itself, its subsidiaries and affiliates, including AXS Group, LLC and others (collectively, “we,” “us,” or the “Company”) is providing this Privacy Notice – Independent Contractors (“Contractor Privacy Notice”) to give its current independent contractors (collectively “Contractors”) information regarding how we collect and use your Personal Data for purposes related to your status as a Contractor with our Company. In this Contractor Privacy Notice, “Personal Data” means data relating to an identified or identifiable individual or household.

SCOPE OF THIS POLICY

This Contractor Privacy Notice applies only to Personal Data collected by us and used in the context of human resources applicable to our current Contractors, and other internal business functions relating to our current Contractors and as noted below, to certain limited information we may have regarding their emergency contacts, including information collected and transmitted through internal computer systems, networks, and online services. Please note, this Contractor Privacy Notice does not apply to our Contractors hired by third party agencies (“Agency Contractors”), which are not Contractors of the Company. We also have the following separate Privacy Notices/Privacy Policies, applicable in various contexts:

AEG Job Applicant Privacy Policy: for U.S. applicants to employment or contractor positions with our Company
AEG HR Privacy Policy: for our Company's current and former U.S. employees

In addition, AEG and AXS each have separate consumer Privacy Policies describing how they collect, use and protect the Personal Data of consumers and users of each of their services.

CATEGORIES OF PERSONAL DATA

This chart describes the categories of Personal Data that we may collect in connection with our current Contractor work relationships (although some of these contexts and purposes may not be applicable to Agency Contractors, to the extent certain purposes are handled by the agency). Note, all Personal Data may be used and disclosed in connection with our Business Purposes.

Category of PI and Representative Data Elements	Context for Collecting and Sharing the PI
Contact Data Honorifics and titles, preferred form of address Mailing address Email address Telephone number Mobile number	We use your Contact Data to communicate with you by mail, email, telephone or text about your relationship with us as a Contractor, including sending you work schedule information, compensation communications and other Company information. Contact Data is also used to help us identify you and personalize our communications, such as by using your preferred name.
Identity Data Full name, nicknames or previous names (such as maiden names) Date of birth Language Company ID number Company account identifiers and passwords System identifiers (e.g., usernames or online credentials)	We use your Identity Data to identify you in our Company records and systems, to communicate with you (often using your Contact Data) and to facilitate our relationship with you, for internal record-keeping and reporting, including for data matching and analytics, to track your use of Company programs and assets, and for most processing purposes described in this Contractor Privacy Notice, including governmental reporting, employment/immigration verification, background checks, etc.
Government ID Data Social security number LLC or similar Tax ID number Driver’s license number Passport number Other government-issued identifiers as may be needed for risk management or compliance (e.g., if you are a licensed professional, we will collect your license number)	We use your Government ID Data to identify you and to maintain the integrity of our HR and other Company records regarding our Contractors, enable prior employment verification and background screening, such as reference checks, license verifications, and criminal records checks, subject to applicable law; enable us to pay you, and to comply with applicable laws, such as reporting compensation to government agencies as required by law, as well as for security and risk management, such as collecting driver’s license data for Contractors who operate Company automobiles, professional license verification, fraud prevention and similar purposes. We may also use Government ID data for other business purposes, such as collecting passport data and secure flight information for Contractors who travel during performance of services for us.
Biographical Data To the extent the following change after onboarding, we may collect: Resume or CV Data from LinkedIn profiles and similar platforms Education and degree information Professional licenses, certifications, memberships and affiliations Personal and professional skills and talents summaries (e.g., languages spoken, CPR certification status, community service participation), interests and hobbies Professional goals and interests	We use Biographical Data to help us understand our Contractors and for professional and personal development, to assess suitability for other job roles, and to ensure a good fit between individuals’ background and relevant additional job functions. We also use Biographical Data to foster a creative, diverse workforce, for coaching, and to guide our decisions about internal programs and service offering
Financial Data Bank account number and details Company-issued payment card information, including transaction records Personal payment card information, if provided for reimbursement Credit history, if a credit check is obtained (only done in limited circumstances)	We use your Financial Data to facilitate compensation, (such as for direct deposits), expense reimbursement, to process financial transactions, and for security and fraud prevention
Health Data Medical information for job placement, including drug testing and fitness to work examinations, accommodation of disabilities Medical information for emergency preparedness programs Dietary restrictions or information	We use your Health Data as needed for internal risk management and analytics related to our human resources functions, staffing needs, and other Business Purpose
Device/Network Data Device information from devices that connect to our networks, whether a Company-owned device, or a personal device System logs, including access logs and records of access attempts Records from access control devices, such as badge readers Information regarding use of IT systems and Internet access, including metadata and other technically generated data, whether using a Company-owned or personal device Records from technology monitoring programs, including suspicious activity alerts Data relating to the use of communications systems and the content of those communications	We use Device/Network Data for system operation and administration, technology and asset management, information security incident detection, assessment, and mitigation and other cybersecurity purposes. We may also use this information to evaluate compliance with Company policies. For example, we may use access logs to verify employee attendance records. Our service providers may use this information to operate systems and services on our behalf, and in connection with service analysis, improvement, or other similar purposes related to our business and HR functions.
Audio/Visual Data Photographs Video images, videoconference records CCTV recordings Call center recordings and call monitoring records Voicemails	We may use Audio/Visual Data for general relationship purposes, such as call recordings used for training, coaching or quality control. We use CCTV recording for premises security purposes and loss prevention. We may also use this information to evaluate compliance with Company policies. For example, we may use CCTV images to verify employee attendance records.
Inference Data Performance reviews Results of tests related to interests and aptitudes	We use inferred and derived data to help tailor professional development programs and to determine suitability for other positions. We may also analyze and aggregate data for workforce planning. Certain inference data may be collected in connection with information security functions, e.g. patterns of usage and cybersecurity risk.
Compliance and Demographic Data Diversity information Employment eligibility verification records, background screening records, and other records maintained to demonstrate compliance with applicable laws, such as payroll tax laws, ADA, FMLA, ERISA et al. Occupational safety records and worker’s compensation program records  Records relating to internal investigations, including compliance hotline reports Records of privacy and security incidents involving Contractor records, including any security breach notifications	We use Compliance and Demographic Data for internal governance, corporate ethics programs, institutional risk management, reporting, demonstrating compliance and accountability externally, to evaluate the diversity of our staff (including Contractors), and as needed for litigation and defense of claims.
Protected Category Data Characteristics of protected classifications under California or federal law, e.g. race, national origin, religion, gender, or sexual orientation.	We use Protected Category Data as needed to facilitate the Contractor relationship, for compliance and legal reporting obligations.
Sensitive Personal Information  Data that, because of its nature, requires defined a heightened degree of care under the CCPA, including without limitation: Social security, driver’s license, state identification card, or passport number; account log-in and password, financial account number; precise location data; racial or ethnic origin, religious or philosophical beliefs, or union membership; the content of certain mail, email and text messages if we are not the intended recipient; the processing of biometric data for the purpose of uniquely identifying a natural person; data concerning health or data concerning a natural person’s sex life or sexual orientation.	We use Sensitive Personal Information as needed to facilitate the Contractor relationship, determine company housing status, for compliance and legal reporting obligations.  We may also use certain data regarding racial or ethnic origin for purposes related to various diversity, equity and inclusion initiatives, and we may sometimes share this information with third party partners.  We may use biometric information to support access controls and integrity of areas or services for authorized users.

Category of PI and Representative Data Elements

Context for Collecting and Sharing the PI

Contact Data

Honorifics and titles, preferred form of address
Mailing address
Email address
Telephone number
Mobile number

We use your Contact Data to communicate with you by mail, email, telephone or text about your relationship with us as a Contractor, including sending you work schedule information, compensation communications and other Company information.

Contact Data is also used to help us identify you and personalize our communications, such as by using your preferred name.

Identity Data

Full name, nicknames or previous names (such as maiden names)
Date of birth
Language
Company ID number
Company account identifiers and passwords
System identifiers (e.g., usernames or online credentials)

We use your Identity Data to identify you in our Company records and systems, to communicate with you (often using your Contact Data) and to facilitate our relationship with you, for internal record-keeping and reporting, including for data matching and analytics, to track your use of Company programs and assets, and for most processing purposes described in this Contractor Privacy Notice, including governmental reporting, employment/immigration verification, background checks, etc.

Government ID Data

Social security number
LLC or similar Tax ID number
Driver’s license number
Passport number
Other government-issued identifiers as may be needed for risk management or compliance (e.g., if you are a licensed professional, we will collect your license number)

We use your Government ID Data to identify you and to maintain the integrity of our HR and other Company records regarding our Contractors, enable prior employment verification and background screening, such as reference checks, license verifications, and criminal records checks, subject to applicable law; enable us to pay you, and to comply with applicable laws, such as reporting compensation to government agencies as required by law, as well as for security and risk management, such as collecting driver’s license data for Contractors who operate Company automobiles, professional license verification, fraud prevention and similar purposes. We may also use Government ID data for other business purposes, such as collecting passport data and secure flight information for Contractors who travel during performance of services for us.

Biographical Data

To the extent the following change after onboarding, we may collect:
Resume or CV
Data from LinkedIn profiles and similar platforms
Education and degree information
Professional licenses, certifications, memberships and affiliations
Personal and professional skills and talents summaries (e.g., languages spoken, CPR certification status, community service participation), interests and hobbies
Professional goals and interests

We use Biographical Data to help us understand our Contractors and for professional and personal development, to assess suitability for other job roles, and to ensure a good fit between individuals’ background and relevant additional job functions.

We also use Biographical Data to foster a creative, diverse workforce, for coaching, and to guide our decisions about internal programs and service offering

Financial Data

Bank account number and details
Company-issued payment card information, including transaction records
Personal payment card information, if provided for reimbursement
Credit history, if a credit check is obtained (only done in limited circumstances)

We use your Financial Data to facilitate compensation, (such as for direct deposits), expense reimbursement, to process financial transactions, and for security and fraud prevention

Health Data

Medical information for job placement, including drug testing and fitness to work examinations, accommodation of disabilities
Medical information for emergency preparedness programs
Dietary restrictions or information

We use your Health Data as needed for internal risk management and analytics related to our human resources functions, staffing needs, and other Business Purpose

Device/Network Data

Device information from devices that connect to our networks, whether a Company-owned device, or a personal device
System logs, including access logs and records of access attempts
Records from access control devices, such as badge readers
Information regarding use of IT systems and Internet access, including metadata and other technically generated data, whether using a Company-owned or personal device
Records from technology monitoring programs, including suspicious activity alerts
Data relating to the use of communications systems and the content of those communications

We use Device/Network Data for system operation and administration, technology and asset management, information security incident detection, assessment, and mitigation and other cybersecurity purposes. We may also use this information to evaluate compliance with Company policies. For example, we may use access logs to verify employee attendance records.

Our service providers may use this information to operate systems and services on our behalf, and in connection with service analysis, improvement, or other similar purposes related to our business and HR functions.

Audio/Visual Data

Photographs
Video images, videoconference records
CCTV recordings
Call center recordings and call monitoring records
Voicemails

We may use Audio/Visual Data for general relationship purposes, such as call recordings used for training, coaching or quality control.

We use CCTV recording for premises security purposes and loss prevention. We may also use this information to evaluate compliance with Company policies. For example, we may use CCTV images to verify employee attendance records.

Inference Data

Performance reviews
Results of tests related to interests and aptitudes

We use inferred and derived data to help tailor professional development programs and to determine suitability for other positions. We may also analyze and aggregate data for workforce planning. Certain inference data may be collected in connection with information security functions, e.g. patterns of usage and cybersecurity risk.

Compliance and Demographic Data

Diversity information
Employment eligibility verification records, background screening records, and other records maintained to demonstrate compliance with applicable laws, such as payroll tax laws, ADA, FMLA, ERISA et al.
Occupational safety records and worker’s compensation program records 
Records relating to internal investigations, including compliance hotline reports
Records of privacy and security incidents involving Contractor records, including any security breach notifications

We use Compliance and Demographic Data for internal governance, corporate ethics programs, institutional risk management, reporting, demonstrating compliance and accountability externally, to evaluate the diversity of our staff (including Contractors), and as needed for litigation and defense of claims.

Protected Category Data

Characteristics of protected classifications under California or federal law, e.g. race, national origin, religion, gender, or sexual orientation.

We use Protected Category Data as needed to facilitate the Contractor relationship, for compliance and legal reporting obligations.

Sensitive Personal Information 

Data that, because of its nature, requires defined a heightened degree of care under the CCPA, including without limitation: Social security, driver’s license, state identification card, or passport number; account log-in and password, financial account number; precise location data; racial or ethnic origin, religious or philosophical beliefs, or union membership; the content of certain mail, email and text messages if we are not the intended recipient; the processing of biometric data for the purpose of uniquely identifying a natural person; data concerning health or data concerning a natural person’s sex life or sexual orientation.

We use Sensitive Personal Information as needed to facilitate the Contractor relationship, determine company housing status, for compliance and legal reporting obligations.  We may also use certain data regarding racial or ethnic origin for purposes related to various diversity, equity and inclusion initiatives, and we may sometimes share this information with third party partners.  We may use biometric information to support access controls and integrity of areas or services for authorized users.

SOURCES OF PERSONAL DATA

We collect Personal Data from various sources, which vary depending on the context in which we process that Personal Data.

Data you provide us – We will receive your Personal Data when you provide them to us, when you complete forms, or otherwise direct information to us.
Data we collect automatically – We may also collect information about or generated by any device you have used to access internal IT services, applications, and networks.
Data we receive from Service Providers – We receive information from service providers performing services on our behalf.
Data we create or infer – We (or third parties operating on our behalf) create and infer Personal Data such as Inference Data based on our observations or analysis of other Personal Data processed under this Privacy Notice, and we may correlate this data with other data we process about you. We may combine Personal Data about you that we receive from you and from third parties.

DISCLOSURE OF PERSONAL DATA

We generally process Personal Data regarding our Contractors internally; however, it may be shared or processed externally by third-party service providers, when required by law or necessary to complete a business function, or in other circumstances described below.

CATEGORIES OF INTERNAL RECIPIENTS

The Personal Data identified below collected from our Contractors may be disclosed to the following categories of recipients in relevant contexts.

Personnel of HR Departments – All Personal Data relating to Human Resources and Recruitment.
Personnel of Finance Departments – Personal Data to the extent related to company and employee transactions .
Direct Supervisors – Elements of Personal Data to the extent permitted in jurisdiction, to the extent necessary to evaluate, establish, and maintain the employment relationship, conduct reviews, handle compliance obligations, and similar matters;
Department managers searching for new employees – Personal data of job candidates contained in job applications to the extent allowed by relevant laws and departmental needs.
Senior Supervisors – Elements of Personal Data to the extent permitted in jurisdiction, to the extent necessary to evaluate, establish, and maintain the employment relationship, conduct reviews, handle compliance obligations, and similar matters.
IT Administrators of AEG and/or third parties who support the management and administration of HR processes may receive Personal Data as necessary for providing relevant IT related support services (conducting IT security measures and IT support services).
Peers and colleagues – Elements of Personal Data, to the extent permitted in jurisdiction, in connection with company address books, intracompany and interpersonal communications, and other contexts relevant to the day- to-day operation of company business.

CATEGORIES OF EXTERNAL RECIPIENTS

AEG may provide HR Personal Data to external third parties as described below. The specific information disclosed may vary depending on context, but will be limited to the extent reasonably appropriate given the purpose of processing and the reasonable requirements of the third party and AEG. We generally provide information to:

Our parent company and other related entities.
Service providers, vendors, and similar data processors that process Personal Data on AEG’s behalf (e.g., analytics companies, financial analysis/budgeting, trainings, benefits administration, payroll administration, etc.).
To prospective seller or buyer of such business or assets in the event AEG sells or buys any business or assets.
To future AEG affiliated entities, if AEG or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its employees will be one of the transferred assets.
To government agencies or departments, employee unions, or similar parties in connection with employment related matters.
To any public authority in relation to national security or law enforcement requests, if AEG is required to disclose Personal Data in response to lawful requests by public authority.
To any other appropriate third party, if AEG is under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect the rights, property, or safety of AEG, our employees, customers, or others.

LOCATIONS OF RECIPIENTS

We and some of our subsidiaries and affiliates are located in the United States, and some of our subsidiaries and affiliates are located in other countries. Any Personal Data collected under this Contractor Privacy Notice from U.S. residents will likely be processed in the United States, however Personal Data may also be processed in other jurisdictions where our affiliates and subsidiaries are located.

PURPOSES FOR COLLECTING, USING, AND DISCLOSING PERSONAL DATA

We collect Personal Data about our current Contractors and other individuals for various general HR and business purposes, as described below. We do not sell or share this Personal Data with third parties in exchange for monetary consideration or for advertising purposes.

GENERAL HR PURPOSES

We collect Personal Data about our current Contractors and other individuals as appropriate in the context of a contractual work relationship including for IT/technical support services, and internal software, networks and devices. The categories of Personal Data we process, along with representative data elements, are listed in the chart below. We generally use, disclose and retain Personal Data processed under this Contractor Privacy Notice for the following HR purposes:

Personal Data pertaining to current  Contractors may be collected, used and shared for:	Staffing and assignments, including scheduling and absence management, Administration of compensation, Time and attendance tracking, expense reimbursement, other workplace administration and facilitating relationships within AEG, IT uses, such as managing our computers and other assets, providing email and other tools to our contractors, Accommodating disabilities, Occupational health and safety programs (including required reporting, disaster and pandemic planning, and incident management), HR support services, such as responding to inquiries, providing information and assistance, and resolving disputes, Risk management, including personnel and premises monitoring (such as in our venues and retail locations), or adjacent to our premises, Providing employment and income verification (as requested by individuals), and Business Purposes.
Personal Data pertaining to former  Contractors may be collected, used and shared for:	Re-engagement, Administration of compensation, For archival and recordkeeping purposes, Providing employment and income verification (as requested by individuals), and Business Purposes
Personal Data pertaining to individuals whose information is provided to us in the course of HR management related to Contractors (such as information pertaining to our Contractors’ emergency contacts, etc.) may be collected, used and shared for:	Administration of compensation, Workplace administration, To comply with child support orders or garnishments, To maintain emergency contact lists and similar records, and Business Purposes.

BUSINESS PURPOSES

Business Purposes” means the following purposes for which Personal Data may be collected, used and shared:

Identity and credential management, including identity verification and authentication, issuing ID card and badges, system administration and management of access credentials,
Security, loss prevention, information security and cybersecurity,
Legal and regulatory compliance, including without limitation, all uses and disclosures of Personal Data that are required by law or for compliance with legally mandated policies and procedures, such as anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines, and other processing in connection with the establishment and defense of legal claims,
Corporate audit, analysis and consolidated reporting,
To enforce our contracts and to protect our Company, our workers, our clients and their employees and the public against injury, theft, legal liability, fraud or abuse, to people or property,
As needed to de-identify Personal Data or create aggregated datasets, such as for consolidating reporting, research or analytics,
Making back-up copies for business continuity and disaster recovery purposes, and other IT support, debugging, security, and operations.
For the analysis and improvement of technical and organizational services, operations, and similar matters; and
As needed to facilitate corporate governance, including mergers, acquisitions and divestitures.

DATA ADMINISTRATION

Security

We require that Personal Data be protected using technical, administrative, and physical safeguards, as described in our various security policies. Our Contractors must follow the security procedures set out in applicable security policies at all times.

Retention and Disposal

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Contractor Privacy Notice, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain Personal Data (without limitation):

Retention periods established under applicable law;
Industry best practices;
Whether the purpose of processing is reasonably likely to justify further processing;
Risks to individual privacy in continued processing;
Applicable data protection impact assessments;
IT systems design considerations/limitations; and
The costs associated continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods. 

YOUR CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act (“CCPA”) and other comprehensive state privacy laws, residents of California may have the following rights, subject to your submission of an appropriately verified request (see below for verification requirements):

Right to Know	You may request any of following, for the 12 month period preceding your request:  (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected, sold or shared your Personal Data; (4) the categories of third parties to whom we have sold or shared your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you
Right to Delete	You have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law.
Right to Correct	You have the right to correct certain Personal Data that we hold about you, subject to exceptions under applicable law.
Right of Non-retaliation	You have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
Direct Marketing	You may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year, if applicable.
Limit Use and Disclosure of Sensitive Personal Information	You may request that we limit our use of Sensitive Personal Information to the specific purposes described in the CCPA.

VERIFICATION OF REQUESTS

Requests to receive a copy of Personal Data, and requests to delete or correct Personal Data, must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data.  If you have one, we may require that you log in through your Company UKG account and/or that you provide the email address we have on file for you (and verify that you can access that email account) as well as other data we have on file, in order to verify your identity.  If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

CONTACT US / DATA INQUIRIES

If you are a current Contractor with access to the Company’s UKG application, you can log in to your Company UKG account to access, obtain copies of, delete, and correct certain Personal Data subject to this Contractor Privacy Notice.  If you do not have access to UKG, please contact us as listed below for assistance with your privacy requests. 

Data Rights Requests: visit our HR Data Request Portal, call 1-888-681-5501, or email hrprivacy@aegworldwide.com.

General Privacy Inquiries: hrprivacy@aegworldwide.com

Please note that we do not sell Personal Data collected in the HR context, nor do we share it for behavioral advertising purposes, so we do not offer the opportunity to opt out of such uses. 