California Consumer (CCPA)

ADDITIONAL NOTICE FOR CALIFORNIA CONSUMERS

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

A.   Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information;
• The specific pieces of information we have collected about you;
• The categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
• The categories of personal information about you that we disclosed for a business purpose.
• The categories of sensitive personal information to be collected and the purposes for which the categories of sensitive personal information are collected or used and whether such information is sold or shared, except for such information that is collected or processed without the purpose of inferring characteristics about you.

We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance.

B. Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected directly from you. If we have received your Personal Information from a Client, we may not be able to delete that Personal Information, as there are business requirements and contracts in place with our Clients that require us to retain some portion of your Personal Information for our financial records and for audit purposes. You may contact us as outlined below to let us know if you want your Personal Information deleted.

C. Right to Opt Out

You have the right to opt out of the disclosure of Personal Information about you for monetary or other valuable consideration. We don’t disclose your Personal Information for monetary or valuable consideration but if this changes, we will update this Privacy Notice and accept your requests regarding your preferences.

D. Right to No Discrimination

We may not discriminate against you because of your exercise of any of the foregoing rights under the CCPA, including by:

• Denying you services;
• Charging different prices or rates for services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of services; or
• Suggesting that you will receive a different price or rate for services or at a different level or quality of services.

We may, however, charge different prices or rates, or provide a different level or quality of services, if that difference is reasonably related to the value provided to us by your personal information.

E. Personal Information We Collect about California Consumers

We describe the personal information we have collected in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled “Types of Information We Collect and Use” above. The information we collect includes the following:

Category of Personal Information Collected	Collected	Sources of Personal Information Collected	Business or Commercial Purpose for Collection	Sold	Shared
Identifiers such as name, address, email address, phone number as described in the “Types of Personal Information We Collect and Use” section above.	Yes	YouAutomatically Third Parties	To provide our products and ServicesTo provide information you request To improve our products and Services To identify potential customers To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To offer employment, to provide insurance and benefits, and for background checks	No	No
The following categories of personal information described in California Civil Code §1798.80€: (1) the personal information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Types of Information We Collect and Use” above.	Yes	YouAutomatically Third Parties	To provide our products and ServicesTo provide information you requested To improve our products and Services To identify potential clients To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To manage payroll and provide and administer employee benefits	No	No
Characteristics of protected classifications under California or federal law that we collect may for employees or prospective employees include Race, Gender, Age, Marital Status, voluntary disability status and Military or Veteran status.	No	N/A	To provide our products and Services to clientsTo improve our products and Services To offer employment, to provide insurance and benefits, and for background checks To comply with law	No	No
Commercial information, including information about services; registration information, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.	Yes	YouAutomatically Third Parties	To provide our products and ServicesTo market our products and Services To improve our products and Services To provide information you requested To comply with law	No	No
Biometric Information.	No	N/A	N/A	No	No
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, mobile apps, advertisements that we display on third party sites and apps, or pages or accounts on any third-party social media platforms.	Yes	Automatically	To provide our products and servicesTo market our products and services To improve our products and services (e.g., usage pattern data) To track employee actions for internal reports and information security purposes	No	Yes (for marketing and analytics)
Geolocation data.	No	Automatically	To market our products and servicesFor detecting security incidents and protecting our Site	No	No
Audio information from calls placed with us.	Yes	Automatically	To provide our products and services	No	No
Professional or employment-related information Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet) and (3) information about consumers preference and behavior that we collect on our websites in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics.	Yes	YouAutomatically Third Parties	To provide our products and Services To offer employment, to provide insurance and benefits, for background checks	No	No
Education information.	No	N/A	N/A	N/A	N/A
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	Yes	Third Parties	To provide our products and servicesTo market our products and services To improve our products and services For detecting security incidents and protecting our Site	No	Yes
Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number.	Yes	You	To provide our products and servicesTo improve our products and services For detecting security incidents and protecting our Site	No	No

We receive some of this Personal Information from our Clients and do not collect it directly from California consumers. For more information, please see “Personal Information We Collect and Use” above.