California Consumer Privacy Act

As of January 1, 2020, California state residents have additional protections under the California Consumer Privacy Act (CCPA). Further information can be found here.

Effective January 1, 2020

A new privacy law that provides California consumers certain rights regarding their personal information became effective on January 1, 2020. However, as of that date the California Attorney General had not completed the rule making process to establish the regulations for businesses to implement the law. Accordingly, we are delaying our full implementation of the law until we have definitive guidance from final regulations, and it will take some time following the date the regulations are final to implement them. In the meantime, we are providing you with notice of the personal information we collect and our purposes for that collection. In addition, if you are a California consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold” (including right to obtain copies of specific pieces and/or information about categories of personal information practices), “right to request deletion of personal information” or “right to opt-out of the sale of personal information” you can contact us here or at 1-877-360-0833 and we will respond to your request as and when we have guidance on how to properly verify you and respond to your requests and are able to do so; however, be advised that these rights do not apply to personal information collected from (a) job applicants, current and former employees and independent contractors (“HR Data Subjects”), or (b) representatives of another business in connection with business communications or transactions (“B-to-B Data Subjects”). We appreciate your patience.

We collect personal information (“PI”) from HR Data Subjects and other consumers (but excluding B-to-B Data Subjects, who are not entitled to this notice) for the following purposes:

 

Category of PI
Examples
Purposes
Identifiers(a) For HR Data Subjects, data collected may include, but is not limited to: name, postal address, alias, unique personal identifier, social security number, passport number, online identifier, email address, and driver’s license number.
(b) For other consumers, data collected may include, but is not limited to: name, unique personal identifier, username, postal address, and email address.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., payroll and other human resources functions),
  • providing benefits, and
  • processing interactions (e.g., managing employee job duties and evaluating performance).
(b) For other consumers, purposes may include, but are not limited to:
  • debugging,
  • security,
  • quality assurance, and
  • performing and delivering products and services.
Personal Records
(a) For HR Data Subjects, data collected may include, but is not limited to: name, postal address, physical characteristics or description, employment history, insurance policy number, bank account number, telephone number, marital status, children’s names, signature, education, and employment.
(b) For other consumers, data collected may include, but is not limited to: name and postal address.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., payroll and other human resources functions),
  • providing benefits, and
  • processing interactions (e.g., managing employee job duties and evaluating performance).
(b) For other consumers, purposes may include, but are not limited to:
  • debugging,
  • security,
  • quality assurance, and
  • performing and delivering products and services.

Personal Characteristics and Traits
(a) For HR Data Subjects, data collected may include, but is not limited to: sex, marital status, veteran status, race, disability, gender identity, religion, and creed.
(b) For other consumers, data collected may include, but is not limited to: gender and ethnicity.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., payroll and other human resources functions),
  • providing benefits, and
  • processing interactions (e.g., administer and maintain group health insurance benefits).
(b) For other consumers, purposes may include, but are not limited to:
  • performing and delivering products and services.
Internet Usage Information
(a) For HR Data Subjects, data collected may include, but is not limited to: interaction with website, cookie information, website history, IP address, browsing time, interaction with application, search history, network interaction history, and browsing history.
(b) For other consumers, data collected may include, but is not limited to: IP address.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., human resources functions),
  • providing benefits, and
  • processing interactions (e.g., managing employee job duties and evaluating performance).
(b) For other consumers, purposes may include, but are not limited to:
  • debugging,
  • security,
  • quality assurance, and
  • performing and delivering products and services.

Geolocation Data
(a) For HR Data Subjects, data collected may include, but is not limited to: precise physical location or movements and travel patterns from company phone.
(b) For other consumers, data collected may include, but is not limited to: precise physical location.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • security.
(b) For other consumers, purposes may include, but are not limited to:
  • providing services to educational institutions.
Sensory Data
(a) For HR Data Subjects, data collected may include, but is not limited to: audio and video recordings of internal meetings;
(b) For other consumers:
not applicable.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services and operations (e.g., training session recordings).
(b) For other consumers: not applicable.
Professional or Employment Information
(a) For HR Data Subjects, data collected may include, but is not limited to: background checks, professional, educational, or employment-related information.
(b) For other consumers, data collected may include, but is not limited to: professional information.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., human resources functions),
  • providing benefits, and
  • processing interactions (e.g., managing employee job duties and evaluating performance).
(b) For other consumers, purposes may include, but are not limited to:
  • performing and delivering products and services.
Non-public Education Records
(a) For HR Data Subjects, data collected may include, but is not limited to: class schedule, class list, and student financial information.
(b) For other consumers, data collected may include, but is not limited to: graduation or dropped date.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., human resources functions),
  • providing benefits, and
  • processing interactions (e.g., managing employee job duties and evaluating performance).
(b) For other consumers, purposes may include, but are not limited to:
  • providing products and services to educational institutions.
Inferences from PI Collected
(a) For HR Data Subjects, data collected may include, but is not limited to: behavior, intelligence, preferences, attitudes, abilities, and aptitudes.
(b) For other consumers, data collected may include, but is not limited to: abilities, characteristics, preferences, and attitudes.
(a) For HR Data Subjects, purposes may include, but are not limited to:
  • performing services (e.g., human resources functions),
  • providing benefits, and
  • processing interactions (e.g., managing employee job duties and evaluating performance).
(b) For other consumers, purposes may include, but are not limited to:
  • debugging,
  • security, and
  • performing and delivering products and services.

 

For additional information on our data practices, including cookies on our web site(s), see our Privacy Policy available here. Although there is not currently a consensus, we do not believe that data collection by third party cookies and similar technologies operating in connection with our online services constitutes a sale by us of your personal information. However, you can learn about how to exercise choices regarding cookies by reviewing our Privacy Policy or visiting www.allaboutcookies.org.We will revise this California Consumer Privacy Act (CCPA) Privacy Notice from time-to-time as the law becomes more clear and we are able to provide you with better information on your CCPA rights and how to exercise them. California consumers have other privacy rights under additional California laws detailed in our Privacy Policy here.