In processing personal data, KES complies with the following principles. Adherence to the principles may be limited in certain cases to the extent necessary to meet national security, public interest, or law enforcement requirements.

Notice
KES notifies all identified data subjects about the purposes for which personal information is collected and used. In certain situations, data is collected, processed, stored and transported in an anonymous format so that the names of the data subjects are not known by data processors within KES. In these cases, data subjects do not need to be notified. Any complaints or inquiries pertaining to KES’s collection of personal information should be directed in writing to the following:

Key Energy Services
1500 Citywest Blvd.
Suite 800
Houston, TX 77042

Choice
KES gives each data subject the opportunity to opt out from allowing KES to disclose his/her personal information to a third party or to use it for a purpose incompatible with the purpose for which it was originally collected or authorized. For Sensitive data, affirmative choice (opt-in) must be given if the data is to be disclosed to a third party or used for a purpose other than its original purpose or the purpose authorized.

Accountability for Onward Transfer (to Third Parties)
KES may transfer information to a third party acting as an agent for KES by making sure that the third party enters into an agreement with KES in which the third party promises that such data may only be processed for limited and specified purposes consistent with the consent provided by the data subject and to provide the same level of protection as required by the principles herein. An example of where this might happen would be in the case of an external benefits administrator who needed personal data in order to process benefits. The third party also promises to notify KES if it makes a determination that it can no longer meet the obligations under these principles and to take reasonable and appropriate steps to stop and remediate any unauthorized Processing. KES agrees to cooperate with affected employees and the applicable third party to remedy any breaches by such third party.

Data Integrity and Purpose Limitation
KES takes reasonable steps to ensure that personal data is accurate, complete, and current. All staff are asked to inform the Human Resources and Payroll Departments immediately in the event of changes in personal information. The personal information collected is limited to the information that is relevant for the purposes of processing and KES will adhere to the principles herein for as long as it retains such information.

Access
Upon request, data subjects may access personal information about them and are able to have inaccurate information corrected, amended or deleted, where information is inaccurate or has been processed in violation of these principles.

Recourse, Enforcement and Liability
Data subjects may contact the Vice President of Human Resources or the General Counsel to register complaints, to submit access requests, or to address any other issues arising under these principles.

Verification
KES conducts a regular self-assessment in order to verify that this Policy on Data Protection and Privacy of Personal Information is published and implemented within KES and that it conforms to the principles herein. As part of this self-assessment, a corporate officer certifies that this Policy of Data Protection and Privacy of Personal Information is accurate, comprehensive, displayed, implemented, and accessible. A corporate officer also certifies that staff have been informed that the policy is located on the KES Intranet and that any dispute resolution necessary to resolve complaints will be handled by the Human Resources Director or Legal Department.

FOR CALIFORNIA RESIDENTS ONLY: Key Energy Services delivers this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). See the following link for more details: (CCPA Policy) Information We May Have Collected: Key Energy may collect the following categories of personal information from you: (1) Identifiers (e.g., a real name, alias, email address); (2) Personal information under Cal. Civ. Code § 1798.80(e) (e.g., a name, address, telephone number); (3) Protected classification characteristics under California or federal law; (4) Professional or employment-related information(e.g., work history, prior employer, information relating to references, resume/CV, details of qualifications, skills and experience); (9) Education information subject to the federal Family Educational Rights and Privacy Act (e.g., student records); and (10) Inferences drawn from other personal information (e.g., profile reflecting a person's preferences or characteristics). Use of Personal Information: Key Energy may use the personal information collected from you for one or more of the following business purposes: (1) to fulfill or meet the purpose for which you provided the information; (2) to process your requests; and (3) to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. *Key Energy does not sell personal information.

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