Electronic Monitoring Notice

Electronic Monitoring Notice Provided to every employee at hiring — New York Civil Rights Law § 52-c

STATUS DRAFT FOR REVIEW BY KING & JURGENS LLC. New York requires private

employers who monitor employee telephone, email or internet access to provide written notice at hiring, obtain written acknowledgement, and post the notice conspicuously. Counsel should confirm the scope of LABAU\u2019s monitoring and the form of this notice before it is issued.

Effective date: ______________________

1. Notice LABAU Holdings, Inc. provides this notice to every employee upon hiring, in accordance with New York Civil Rights Law § 52-c. Any and all telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by an employee by any electronic device or system — including but not limited to the use of a computer, telephone, wire, radio or electromagnetic, photoelectronic or photo-optical systems — may be subject to monitoring at any and all times and by any lawful means.

2. What LABAU Actually Monitors The statutory language above is broad. What follows is what LABAU does in practice, so that no employee is left guessing.

SYSTEM

WHAT IS MONITORED

WHY

Company email and

Content is retained and may be accessed by the

Security, legal obligations, and

messaging

Company

continuity when someone is unavailable

Company-issued devices

Device status, application inventory, compliance

Securing devices that hold or reach

state, location where the device is enrolled in

member and partner information

management Operations admin panel

Every action taken is recorded in an immutable

Member privacy. Access to member

audit log, with the account and timestamp

records is logged so that it can be reviewed.

SYSTEM

WHAT IS MONITORED

WHY

Platform and system access

Sign-in records, access logs, and administrative

Security and fraud prevention

actions Support and member calls

Calls handled through the contracted support

Service quality and dispute resolution

service may be recorded

3. What LABAU Does Not Monitor · LABAU does not monitor personal devices, personal email accounts or personal social media · LABAU does not track employee location outside working hours · LABAU does not use keystroke logging, screen recording or webcam monitoring · LABAU does not use monitoring data to evaluate productivity or to rank employees against one another · LABAU does not read the content of an employee’s communications as a matter of routine. Access to communication content occurs only for a specific reason — a security investigation, a legal obligation, or continuity of an active matter — and is recorded. The last point matters most. Monitoring here means logging and retention, not surveillance. An employee should assume that what they do on Company systems is recorded, and also that nobody is reading it absent a reason.

4. Member Privacy The audit log on the operations admin panel exists for the benefit of members rather than as a control on employees. LABAU members are among the most privacy-sensitive individuals in New York. Every access to a member record is logged so that it can be reviewed if a question ever arises about who looked at what. Employees should understand this as a protection for them as much as for the member. A logged access that had a legitimate reason is evidence that it was legitimate.

5. W-2 employees This notice is provided to employees. LABAU Concierge Drivers are salaried W-2 employees of LABAU and are not employees of LABAU. Data collected in connection with driver services — device status, location while on duty, verification records and delivery evidence — is described in the LABAU Driver Privacy Statement and the LABAU Biometric Data Policy rather than in this notice.

6. Questions

Any question about this notice, about what is monitored, or about a specific access to a record may be raised with the Chief Executive Officer directly. An employee may ask whether a particular record was accessed and by whom, and will be told. LABAU Holdings, Inc. · kristina@labauholdings.com · New York, New York

Employee Acknowledgement I acknowledge that I have received the LABAU Holdings, Inc. Electronic Monitoring Notice at the time of my hiring, and that I have read and understood it.

Signature: ______________________________________ Printed Name: __________________________________ Position: ____________________________________ Date of hire: __________________________ Date acknowledged: ________________________

LABAU HOLDINGS, INC. Signature: ______________________________________ Printed Name: Kristina Charles Title: Founder & Chief Executive Officer Date: ____________________________

Posting Requirement New York requires this notice to be posted conspicuously in a place readily available for viewing by employees, in addition to being provided at hiring. LABAU is remote-first with no office, so the notice is posted in the location employees actually use: the shared company workspace, visible without searching for it, and re-surfaced to each employee annually. Counsel should confirm that this satisfies the posting requirement for a remote employer.

Signed acknowledgements are retained in the employee file for the duration of employment and for the period afterwards required by law.