CATEGORY EXAMPLES COLLECTED?A. Identifiers 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. YESB. 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.YESC. Protected classification characteristics under California or federal lawAge (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, and genetic information (including familial genetic information).YESD. Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YESE. Biometric informationGenetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints.YESF. Internet or other similar network activityBrowsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YESG. Geolocation dataPhysical location or movements.YESH. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.YESI. Professional or employment-related informationCurrent or past job history or performance evaluations.YESJ. 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.YESK. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES
PERSONAL INFORMATION DOES NOT INCLUDE:
Publicly available information from government records
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 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
WE OBTAIN THE CATEGORIES OF PERSONAL INFORMATION LISTED ABOVE FROM THE FOLLOWING CATEGORIES OF SOURCES:
Directly from our clients, prospects, or employees. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients, prospects, or their employees. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website (www.vensure.com) or other portals. For example, from submissions through our website or website usage details collected automatically.
From third parties that interact with us in connection with the services we provide. For example, from government agencies when we verify data associated with payroll processing and withholding tax payments.
We may also collect personal information about you from other categories of sources, such as: our affiliates; our other clients; public and publicly available sources; our third-party referral partners, vendors, data suppliers, and service providers; partners with which we offer co-branded services or engage in joint event or marketing activities; social networks; news outlets and related media; and organizations with which you are employed or affiliated.
Use of Personal Information
WE MAY USE OR DISCLOSE THE PERSONAL INFORMATION WE COLLECT FOR ONE OR MORE OF THE FOLLOWING BUSINESS PURPOSES:
To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
To provide you with information, products, or services that you request from us.
To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
To operate, manage, and maintain our business.
To accomplish our business purposes and objectives.
To communicate with you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis, and service offering development.
For vendor management purposes.
As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information
held by us is among the assets transferred.
We 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
WE DO NOT, AND WILL NOT, SELL YOUR PERSONAL INFORMATION.
We may share your personal information within the Lightsource HR family of companies to provide services to you or in an effort to assess your needs and how we can help fulfill those needs.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we require the recipient to keep that personal information confidential and secure, to not disclose that personal information to others, and to not use it for any purpose except performing the services related to the business purpose.
IN THE PRECEDING TWELVE (12) MONTHS, WE HAVE DISCLOSED THE FOLLOWING CATEGORIES OF PERSONAL INFORMATION FOR A BUSINESS
Category A: Identifiers
Category B: California Customer Records Personal Information Categories
Category C: Protected Classification Characteristics Under California or Federal Law
Category D: Commercial Information
Category E: Biometric Information
Category F: Internet or Other Electronic Network Activity Information
Category G: Geolocation Data
Category I: Professional or Employment-Related Information
Category K: Inferences Drawn from Other Personal Information
WE DISCLOSE YOUR PERSONAL INFORMATION FOR A BUSINESS PURPOSE TO OUR AFFILIATES AND/OR TO ONE OR MORE OF THE FOLLOWING CATEGORIES OF THIRD PARTIES:
Third-party service providers.
Administrators authorized by your organization.
Licensors or third-party applications (if you access a third-party application on our services through a license agreement with a licensor).
Other parties where required by law or to protect our rights.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information to third parties within the scope of the application of the CCPA.
Your Rights and Choices
The CCPA provides California consumers 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 we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.
ONCE WE RECEIVE AND CONFIRM YOUR VERIFIABLE CONSUMER REQUEST, 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 sharing that personal information.
The affiliates with whom we shared your 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 disclosed your personal information to a third party for a business purpose, separate lists identifying the personal information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that we 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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
WE MAY DENY YOUR DELETION REQUEST IF RETAINING THE INFORMATION IS NECESSARY FOR US OR OUR SERVICE PROVIDERS TO:
Complete the transaction for which we collected the personal information, provide a product 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.
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 seq.).
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
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 ONLY MAKE A VERIFIABLE CONSUMER REQUEST FOR ACCESS OR DATA PORTABILITY TWICE WITHIN A TWELVE (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 that you are an authorized representative of a person about whom we collected personal information.
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. 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 (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (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 usable and should allow you to transmit the information from one entity to another 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 products or services.
Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of products or services.
Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
How to Make a Request
You may make a request for the disclosures or deletion described above by contacting us using one of the methods described below methods.
You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request ifwe are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.
We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the (FCRA), (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or the California Constitution.
Changes to Our Privacy Notice
At a minimum, this notice will be reviewed and updated on an annual basis. We reserve the right to amend this notice at our discretion and at any time. Any changes will be posted on this page with an updated revision date.