PRIVACY POLICY
PRIVACY NOTICE FOR CALIFORNIA EMPLOYEES
This Privacy Notice for California Residents applies solely to employees who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:
CATEGORY |
EXAMPLES |
COLLECTED |
|---|---|---|
|
A. Identifiers
|
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|
YES
|
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
|
YES
|
|
C. Protected classification characteristics under California or federal law.
|
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|
YES
|
|
D. Commercial information.
|
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|
NO
|
|
E. Biometric information.
|
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information,such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|
YES
|
|
F. Internet or other similar network activity.
|
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|
YES
|
|
G. Geolocation data
|
Physical location or movements.
|
YES
|
|
H. Sensory data.
|
Audio, electronic, visual, thermal, olfactory, or similar information.
|
YES
|
|
I. Professional or employment-related information.
|
Current or past job history or performance evaluations.
|
YES
|
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
|
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|
YES
|
|
K. Inferences drawn from other personal information.
|
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|
YES
|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or services we provide to you.
- Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
- Third parties, including recruiters who submit your information to us, and consumer reporting agencies for employment background checks.
We may use or disclose the personal information we collect for one or more of the following business purposes:
- Fulfill or meet the purpose for which you provided the information
- Contact you
- Accomplish administrative functions
- Conduct background screening and facilitate hiring
- Process payroll
- Respond to your inquiries
- Recruit employees
- Administer benefits
- Pay and reimburse expenses
- Conduct performance reviews
- Conduct employee training
- Monitor work-related licenses and credentials
- Provide human resources management services
- Assist you in case of emergency
- Monitor eligibility to work in the U.S.
- Facilitate a better working environment
- Ensure a safe and efficient working environment
- Maintain security on company website and internet connected assets
- Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- Determine whether you may be displaying symptoms of Covid-19 or may have recently been exposed to Covid-19
- Otherwise as described to you when collecting your personal information or as set forth in the CCPA
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other Personal Information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
- Law enforcement or governmental authorities as required.
In the preceding twelve (12) months, we have not sold any personal information.
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact Human Resources at 805 483 1000 or [email protected].