California Privacy Notice
This notice to California Residents pursuant to the California Consumer Privacy Act and the California Privacy Rights Act applies solely to website visitors, employees, visitors, and other individuals 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”), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”) and other California privacy laws. Any terms defined in the CCPA and CPRA have the same meaning when used in this notice.
Information We Collect
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 (“personal information”). We have collected the following categories of personal information on consumers as defined under the CCPA and CPRA within the last twelve (12) months:
|Category||Examples||Possibly collected or shared for a business purpose in the last twelve (12) months.|
|A. Identifiers||A real name, IP address, email address, or other similar identifiers.||Yes|
B. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))
|From our employees and applicants: A name, signature, Social Security Number, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment history, medical information, or health insurance information.
From our business contacts (e.g., clients and consultants): A bank account number, credit card number, or other financial information.
|C. Protected classification characteristics under California or Federal Law||Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy, childbirth and related medical conditions), sexual orientation, veteran or military status, 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, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or similar network activity||Information regarding a consumer’s interaction with an Internet website.||Yes|
|G. Geolocation Data||Physical location or movements||Yes|
H. Sensory Data
|Audio, electronic, visual, thermal, olfactory, or similar information.||No|
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 1232(g); 34 CFR Part 99)
|Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
Personal information does not include:
- Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s or CPRA’s scope, including: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) 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.
- Directly from you. For example, from forms you complete on our website or job application portal.
- We retain your data pursuant to our records retention policy.
Use of Personal Information
- To fulfill or meet the reason you provided the information. For example, if you share your name, contact information, and resume to be considered for a job posting, we will use that personal information in evaluating your qualifications for that position.
- To collect payment from our clients.
- To provide payment to our consultants, vendors, and service providers.
- To respond to inquiries.
- To reach out for recruitment purposes.
- To respond to law enforcement requests and as required by applicable law, court order, or government regulations.
- For other legitimate business purposes.
Disclosure of Personal Information
We may disclose your personal information to a third-party contractor or service provider 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 may have disclosed the following categories (corresponding with the table above) of personal information for a business purpose: Category A, Category B, Category C, and Category I.
We disclose your personal information with the following categories of third parties: our service providers, and third parties to whom you or your agents authorize us to disclose your personal information in connection with services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights Under the CCPA and CPRA
- The categories of personal information and sensitive information we collected about you.
- The categories of sources for the personal and sensitive information we collected about you.
- Our business or commercial purpose for collecting, using and/or disclosing that information.
- The categories of third parties, contractors and service providers with whom we share, sell or disclose that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, a list of those disclosures, identifying the personal information categories that each category of recipient obtained.
- Whether your information is sold or shared.
- The retention period or criteria used for retention.
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Deny you services.
- Provide you a different level of service.
- Discriminate in making employment decisions.
- Provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We may make changes to this notice. Notification of changes will be posted on this page. You should review this notice periodically to keep up to date on our most current policies and practices.
Date of Last Update: December 15, 2022