PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
PURSUANT TO THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)
Effective Date: 01/01/2020
Last Reviewed on: 07/01/2021
This Privacy Notice for California Residents supplements the information contained in Career Strategies Inc.’s (“Company”) Privacy Notice and applies solely to all visitors, users, and others 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 any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
Company collects 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, the Company has collected the following categories of personal information from its consumers within the last twelve (12) months:
|A. Identifiers and Contact Information.||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.
|C. Protected classifications and 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, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes, in-house employees|
|G. Geolocation data.||Physical location or movements.||No|
|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|
|L. Family Information||Contact information for family members listed as emergency contacts, contact information for dependents and other dependent information, medical and health information for family members related to COVID-19 symptoms, exposure, or testing, and family travel information.||Yes|
|M. Information of Friends, Co-workers, and Other
Associates or Individuals with Whom You Have Been in Close Contact within the Past 14 Days
|Medical and health information for friends, co-workers, and other associates or individuals related to COVID19 symptoms and their travel information
|N. Medical and Health Information||Your body temperature, COVID-19 diagnosis, COVID-19 related testing results, whether you have or display certain symptoms such as fatigue, cough, sneezing, aches and pains, runny or stuffy nose, sore throat, diarrhea, headaches, sudden loss of smell or taste, or shortness of breath, whether you have been in close contact in the last 14 days with anyone who has exhibited any of these symptoms, whether you have been in close contact in the last 14 days with anyone who has tested positive for COVID-19, any COVID-19-related doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, and correspondence with you and your healthcare provider(s) regarding any request for accommodation or medical leave of absence related to COVID-19, COVID19 vaccination-related information||Yes|
|O. Workers Comp Information||Medical information related to work-related injuries, medical accommodations, length of time needed for treatment, prognosis, cause, and related medical examinations||Yes|
|P. Travel Information||Whether an employee has recently traveled to a restricted area that is under a Travel Advisory, locations traveled to within the 14 days prior to coming to the workplace and the dates spent in those locations||Yes|
Personal information does not include:
- Publicly available information from government records.
- Deidentified 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.
The Company obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, via a computer monitoring system called Activtrak (in-house employees only)
- Third-parties (e.g., background check service providers)
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To receive and evaluate job applications;
- For internal human resources purposes, such as measuring employee engagement, employee satisfaction, and employee performance.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our employees is among the assets transferred.
COVID-19 Related Information
The Company is implementing procedures to (a) require all employees at certain times or upon certain events to be tested for the COVID-19 virus, (b) measure the temperature of all individuals coming into the Company’s facility, (c) inquire and observe whether any individual, whether an employee or visitor, attempting to enter a Company facility has any symptoms of COVID-19 or related illness and/or (d) inquiring about the COVID-19 vaccination status of any individual entering the Company facility. Pursuant to the CCPA, we are notifying you that in the process if taking the above steps, the Company is or may be collecting the following categories of Personal Information:
- Personal Identifiers & Contact Information (e.g., name, alias, postal or mailing address, email address, telephone number);
- Physical Characteristics or Description (e.g., eye color, hair color, hair style, height, weight, build);
- Family Information (e.g., contact information for family members listed as emergency contacts, contact information for dependents and other dependent information, medical and health information for family members related to COVID-19 symptoms, exposure, or testing, and family travel information);
- Information of Friends, Co-workers, and Other Associates or Individuals with Whom You Have Been in Close Contact within the Past 14 Days (e.g., medical and health information for friends, co-workers, and other associates or individuals related to COVID19 symptoms and their travel information);
- Protected Classifications (e.g., race, ethnicity, national origin, sex, gender, age, disability, medical or mental condition, familial status);
- Medical and Health Information (e.g., your body temperature, COVID-19 diagnosis, COVID-19 related testing results, whether you have or display certain symptoms such as fatigue, cough, sneezing, aches and pains, runny or stuffy nose, sore throat, diarrhea, headaches, sudden loss of smell or taste, or shortness of breath, whether you have been in close contact in the last 14 days with anyone who has exhibited any of these symptoms, whether you have been in close contact in the last 14 days with anyone who has tested positive for COVID-19, any COVID-19-related doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, and correspondence with you and your healthcare provider(s) regarding any request for accommodation or medical leave of absence related to COVID-19, COVID19 vaccination-related information); and
- Travel Information (e.g., whether you have recently traveled to a restricted area that is under a Travel Advisory, locations traveled to within the 14 days prior to coming to the workplace and the dates spent in those locations).
The Company may collect Personal Information for any of the following business purposes:
- To reduce the risk of spreading of COVID-19 in and through the workplace;
- To protect employees and visitors in the workplace from exposure to COVID-19;
- To comply with local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19;
- To identify potential symptoms linked to COVID-19 (including through temperature checks, antibody testing, or COVID-19 questionnaire);
- To permit contact tracing relating to any potential exposure to COVID-19;
- To communicate with employees and visitors regarding potential exposure to COVID-19 properly warn others who have had close contact with an infected or symptomatic individual so that they may take precautionary measures, help prevent further spread of the virus, and obtain treatment, if necessary.
The Company will maintain this information under strict confidentiality. The Company 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.
Sharing Personal Information
The Company 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.
We share your personal information with the following categories of third parties:
- Service providers.
- As required to be produced by applicable law.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers and Contact Information
- Category B: California Customer Records personal information categories
- Category C: Protected classification characteristics under California or federal law
- Category F: Internet or other similar browsing activity.
- Category H: Sensory data
- Category I: Professional or employment-related information
- Category J: Non-public education information
- Category K: Inferences drawn from other personal information
- Category L: Family Information
- Category M: Information of Friends, Co-workers, and Other Associates or Individuals with Whom You Have Been in Close Contact within the Past 14 Days
- Category N: Medical and Health Information
- Category O: Workers Compensation Information
- Category P: Travel Information
- We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Clients, as applicable
- As legally required to produce, under subpoena, or court order.
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records. In certain cases, your request may be denied on the basis of a legitimate exception or where we are legally prevented from honoring such request.
We may deny your deletion request if retaining the information is lawful and necessary for us or our service provider(s) to:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- 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.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 877-778-1199
- Or email at email@example.com from your personal email address on file
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient 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 cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Career Strategies, Inc.
Attn: Human Resources Dept.
719 N Victory Blvd
Burbank, CA 91502