Effective Date: February 28, 2023

Dear Employee/Applicant:

At, LLC, and its operating groups, parents, subsidiaries, affiliates, and related entities, (“,” the “Company,” “we” or “us”) we are committed to the proper handling of the Personal Information collected or processed in connection with your employment with us. We provide the following notice to all Company employees, job applicants, and independent contractors residing in California. We may provide your personal information to those providing services for us, such as our benefits administrators or other entities that need the information to provide a business function for us, or to government agencies (such as taxing authorities and the social security administration).

This disclosure describes the categories of Personal Information we collect and the purposes for which we process that information in accordance with California Civil Code § 1798.100(a) of the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). The CCPA defines “Personal Information” as categories of information that identify, relate to, describe, or are reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to a particular individual or household.

Please note that the CCPA’s definition of Personal Information does not include publicly available information lawfully made available to the general public from federal, state, or local government records (information is not publicly available if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained), 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 Accessibility Act of 1966 (HIPAA), the California Medical Information Act (CMIA) or clinical trial data, or personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sources of Personal Information

Our sources of Personal Information can be directly from you, or we may also combine Personal Information collected from other sources with the Personal Information you provide to us. In some instances, Personal Information may be collected automatically, such as in connection with your use of the internet on company devices, or via timekeeping applications or key fob access. The sources of your Personal Information may include:

  • You
  • Recruiters
  • Prior employers (e.g., for references)
  • Professional references you provide to us
  • Educational institutions
  • Pre-employment screening services
  • Job posting and talent acquisition sites or services (e.g., LinkedIn, Indeed, Monster, etc.)
  • Credentialing and licensing organizations
  • Publicly available resources including your social media profile (e.g., LinkedIn, Twitter, Facebook) or your current employer’s website
  • Third parties as necessary for providing you with benefits and ancillary services
  • Your Company-owned or Company-controlled device (such as computers and phones)
  • Other sources as directed by you.

Categories of Personal Information Collected

In connection with your application for employment or your employment with the Company, the Company provides the following list of categories of Personal Information (as set forth in California Civil Code sections 1798.140(v)(1)(A) through (L), effective January 1, 2023) that are collected from you, and whether or not those categories are sold or shared as defined in the CPRA. Please note that the definition of “sale” may include the sharing of information for non-monetary value, but the definition of “sharing” under the CPRA applies only to the sharing of that information for cross-context behavioral advertising.

While we do not sell or share your personal information for monetary purposes, the definition of “sale” in California includes the sharing of personal information for targeted advertising and analytics. Because we use companies like Google Analytics and Facebook, our non-monetary uses of your personal information may be considered a “sale” under the CCPA. You may contact us to opt out of the sharing of your information for this purpose. You also may contact us to limit the use of your sensitive personal information, specifically, your geolocation information, if you have enabled it. We never share your Social Security Number for any purpose other than the purpose for which you provided it to us.

Category Examples of this Category Sources of Personal Information Collected Y/N “Sold” under CPRA Shared for Cross-Context Behavioral Advertising
A. Identifiers (Cal. Civ. Code 1798.140(v)(1)(A)) Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. YOU
Yes Yes No
B. Personal information described in California Civ. Code § 1798.80(e) (the Customer Records statute) 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 in this category may overlap with other categories. YOU
Yes Yes No
C. Characteristics of protected classifications under California or federal law Cal. Civ. Code 1798.140(v)(1)(C)) Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), 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), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking. YOU
Yes No No
D. Commercial information (Cal. Civ. Code 1798.140(v)(1)(D)) Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YOU
Yes Yes No
E. Biometric information (Cal. Civ. Code 1798.140(v)(1)(E) as defined in Cal. Civ. Code 1798.140(c)) An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns that can be used to establish individual identity, including images of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information. YOU
Yes, in the context of recorded customer care calls and the surveillance of public workspaces Yes No
F. Internet or other electronic network activity information (Cal. Civ. Code 1798.140(v)(1)(F)) Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. AUTOMATICALLY Yes Yes Yes
G. Geolocation data (Cal. Civ. Code 1798.140(v)(1)(G)) Physical location and/or movements. N/A No No No
H. Sensory data (Cal. Civ. Code 1798.140(v)(1)(H)) Audio, electronic, visual, thermal, olfactory, or similar information. YOU
Yes, in the context of recorded customer care calls and the surveillance of public workspaces Yes No
I. Professional or employment related information (Cal. Civ. Code 1798.140(v)(1)(I)) Current or past job history or performance evaluations YOU
THIRD PARTIES (e.g., from references)
Yes (for employees and job applicants) No No
J. Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. §1232g, 34 CFR Part 99) (Cal. Civ. Code 1798.140(v)(1)(J)) 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. YOU
THIRD PARTIES (to verify degrees or for background checks)
Yes No No
K. Inferences drawn from other personal information Cal. Civ. Code 1798.140(v)(1)(K)) Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YOU
Yes No No
L. Sensitive Personal Information (Cal. Civ. Code 1798.140(v)(1)(L)) Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data YOU
Yes No No

Use of Your Personal Information

We use the information collected for the purposes stated below:

For Job Applicants:

  • To recruit employees, including evaluation of marketing and job offering services, website traffic, and referral sources;
  • To process your application for employment;
  • To conduct employment-related background screening and/or reference checks;
  • To send you correspondence and information relating to your application or your employment with the Company;
  • To verify your identity, citizenship, or legal right to work for the Company, or to assist or cooperate with obtaining relevant immigration documents;
  • To verify your educational background and/or degrees, certifications, or qualifications for the position you apply for;
  • To verify your prior employment;
  • To offer you employment with Company;
  • For testing, evaluation and/or reporting metrics, including but not limited to aggregating or anonymizing such information for workforce analytics, data analytics, and benchmarking;
  • To comply with applicable law or regulatory requirements, including legal requirements under state and federal law, law enforcement investigations or inquiries, as well as internal company reporting obligations, such as diversity, equity and inclusion initiatives and/or Equal Employment Opportunity Act reporting obligations;
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity;
  • For quality assurance purposes, including call monitoring or customer service, and debugging to identify and repair errors that impair existing intended functionality;
  • For auditing related to a current interaction with the applicant or employee and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with this and other standards;
  • To analyze the effectiveness of placement of job listings and job descriptions;
  • For fraud prevention; and
  • For internal research for technological development and demonstration.

For Employees, Contractors, and Past Employees/Contractors:

All of the above, plus:

  • To track time and attendance;
  • To administer employee benefits, such as medical, dental, commuter and retirement benefits, including the recording and processing of eligibility of dependents and beneficiaries, absence and leave monitoring, insurance and accident management, and rewards or discount programs offered to employees;
  • To provide healthcare-related services, such as accommodations and/or services based on eligibility (e.g., disability, worker’s compensation, medical condition);
  • To provide payroll, invoice, and tax services, including reimbursement for expenses, salary administration, payroll management, payment of expenses, payment of state and/or federal income taxes (if applicable), social security and unemployment taxes, and to administer other compensation-related payments, including bonuses and equity, if applicable;
  • To conduct performance-related reviews, including performance appraisals, professional development, career planning, skills monitoring, job moves, promotions and staff re-structuring;
  • To monitor work-related licenses and credentials and ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies or governing agencies;
  • To provide employees with other employment-related services, such as handling of employees’ claims, travel for the Company, moving or relocation services, or administration of separation from employment;
  • To assist you in case of an emergency, including maintaining contact information for you, your partner or spouse, and/or your dependents in case of personal or business emergency;
  • To maintain the safety and security of our employees, residents, tenants, contractors, visitors and others, including maintenance of security on Company websites, apps, intranets and/or extranets (such as monitoring email and internet access, and ensuring secure network access and data integrity), maintenance of physical security (including controlled entry to Company worksites and/or real estate assets), monitoring of worksite locations and/or real estate assets, including using biometrics or location monitoring for keys, key fob or key card entry to Company property, ensuring that employees, contractors and visitors comply with all applicable safety regulations;
  • In connection with audiovisual surveillance of public spaces;
  • For internal company directories;
  • For video presentations, interviews, training materials, and/or web conferences within the scope of your employment or contract;
  • For the tracking of Company-owned or Company-leased vehicles, computers, equipment, and devices, including, but not limited to, remote deletion of Company data on business or personal devices;
  • For verification of proper use of Company resources;
  • To facilitate a better working environment;
  • To maintain commercial insurance policies and overages, including for workers’ compensation and other liability insurance; and
  • For other purposes stated at or before the time of the collection of the information.

Further, please note that under the CPRA, we may use your personal information for Company business or other notified purposes, provided that the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed. /p>

Collection and Use of Sensitive Personal Information:

We only collect your Sensitive Personal Information in order to enroll and administer benefits to you, to fulfill our contract with you, and for general human resource purposes. We share this information with our Professional Employer Organization (PEO), currently Justworks. We do not collect your Sensitive Personal Information for the purpose of inferring characteristics about you.

Retention Schedule

We retain information related to applications for employment for two years after your application.

We retain information related to your employment for the term of your employment and for 6 years thereafter. Some information, such as contact information, tax information, or historical information about your employment with the Company, may be retained indefinitely for the integrity of our databases and our reporting requirements.

Third Parties with whom you have directly shared information during the term of your employment (e.g., benefits organizations) may have a different retention schedule for the information you have provided to them.

Your Rights Under the CPRA

Under the CPRA, you have several rights concerning the personal information collected by us. Upon the receipt of a verifiable employee request, we will use commercially reasonable efforts to honor your exercise the rights below, unless there is a business reason exception, or if your exercise of the rights is impossible or otherwise involves a disproportionate effort. We will let you know in writing if we are unable to process your request.

California residents have the following rights:

  • To know the categories of personal information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;
  • To know if sensitive personal information is being collected about you, the categories of sensitive personal information being collected, the purposes for which the categories of sensitive personal information are collected or used, and whether the sensitive personal information is sold or shared;
  • To know the length of time we intend to retain each category of personal information;
  • To know whether your personal information is sold or disclosed and to whom;
  • To access your personal information;
  • To delete the information you have provided to us, with certain exceptions;
  • To correct your personal information if it is inaccurate;
  • To limit the use of your sensitive personal information;
  • To reject automated decision making and profiling;
  • To access information about automated decision making;
  • To opt out of the sale or sharing of your personal information; and
  • Not to be discriminated against, even if you exercise your privacy rights.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

If you are a current employee, you are required to keep your personal information updated by using JustWorks, contacting your supervisor, or contacting the Director of Administration.

If you have any questions regarding the collection of your Personal Information, please visit our website and review our Privacy Policy here or contact the Director of Administration.