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Supplemental California Privacy Notice

For Applicants, Employees, and Business-to-Business Contacts

Effective Date: April 2, 2024

The California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “CCPA”), gives California residents certain rights and requires businesses to make certain disclosures regarding their collection, use, and disclosure of Personal Information. This California Supplemental California Privacy Notice (“California Privacy Notice”) provides such notice to Source4Solutions, LLC (“ESS,” “we,” “us,” “our”) California resident job applicants (“applicants”), California resident employees, independent contractors, and other individuals who interact with ESS in an employment-related capacity (collectively, “employees”), and California residents who interact with ESS in a business-to-business capacity including teachers, school or educational staff, or others who similarly interact with ESS in a business-to-business capacity (collectively “B2B contacts”).

Please note that this California Privacy Notice only addresses ESS’s collection, use, and disclosure of Personal Information on applicants, employees and B2B contacts who are residents of California and does not apply to individuals who are residents of other U.S. states or other countries. For further details about our privacy practices, please see our Privacy Policy.

If you are unable to review or access this notice due to a disability, you may contact ESS at Legal@ess.com or (844) 482-0300 to access this notice in an alternative format.

Definitions

As used in this California Privacy Notice:

  • Personal Information: “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes Sensitive Personal Information but does not include protected health information covered by the Health Information Portability and Accountability Act (“HIPAA”), nonpublic personal information under the Gramm-Leach-Bliley Act (“GLBA”), or any other information which is exempt from the CCPA.
  • Sensitive Personal Information: “Sensitive Personal Information” includes Personal Information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a consumer’s mail, email, and text messages, unless ESS is the intended recipient of the communication. Sensitive Personal Information also includes information concerning health, sex life, or sexual orientation.
  • Vendor: “Vendor” means a ‘service provider’ or ‘contractor’ as those terms are defined in the CCPA.
  • Other CCPA Definitions: The terms “Collect,” “Processing,” “Service Provider,” “Third Party,” “Sale,” “Share,” “Consumer,” and other terms defined in the CCPA and their conjugates, have the meanings afforded to them in the CCPA, whether or not such terms are capitalized herein, unless contrary to the meaning thereof.

Collection, Use, and Disclosure of Personal Information

Information About the Processing of Your Personal Information

Information regarding the Personal Information we collect from and about applicants, employees and B2B contacts—including the categories of Personal Information collected, the sources from which we collect your Personal Information, the purposes for collecting and disclosing your Personal Information, and the categories of third parties to whom we may disclose your Personal Information—is provided in the appendices to this California Privacy Notice.

We Do Not Sell or Share Applicant, Employee, or B2B Personal Information

We have not sold or shared Personal Information about California applicants or employees. Further, we do not have actual knowledge that we sell or share Personal Information of California consumers (including applicants and employees) under 16 years of age. For purposes of the CCPA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Retention of Personal Information

We retain each of the categories of Personal Information listed in the appendices to this California Privacy Notice for the duration of your applicant, employee and/or B2B contact relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes. We consider the following criteria when determining how long to retain Personal Information: why we collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information, and risks associated with retaining the Personal Information.

Your Rights

Data Subject Rights Available to You

As an applicant, employee, or B2B contact you have the following rights regarding the collection and use of your Personal Information, subject to certain exceptions:

  • Right to Receive Information on Privacy Practices: You have the right to receive the following information at or before the point of collection:
    • The categories of Personal Information to be collected;
    • The purposes for which the categories of Personal Information are collected or used;
    • Whether or not that Personal Information is Sold or Shared;
    • If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and
    • The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this California Privacy Notice, and you may request further information about our privacy practices by contacting us as at the contact information provided below.

  • Right to Deletion: You may request that we delete any Personal Information about you that we collected from you.
  • Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
  • Right to Know: You may request that we provide you with the following information about how we have handled your Personal Information in the 12 months preceding your request:
    > The categories of Personal Information we collected about you;
    > The categories of sources from which we collected such Personal Information;
    > The business or commercial purpose for collecting, Selling, or Sharing Personal Information about you;
    > The categories of Third Parties with whom we disclosed such Personal Information; and
    > The specific pieces of Personal Information we have collected about you.
  • Right to Receive Information About Onward Disclosures: You may request that we disclose to you:
    > The categories of Personal Information that we have collected about you;
    > The categories of Personal Information that we have Sold or Shared about you and the categories of Third Parties to whom the Personal Information was Sold or Shared; and
    > The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
  • Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights. For example, we will not make hiring, firing, promotion, or disciplinary decisions based on or in consideration of your exercise of your data subject rights.
  • Rights to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sale and Sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. We do not Sell or Share the Personal Information of employees or applicants, but we may Sell or Share the Personal Information of B2B contacts. We do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA.

Exercising Data Subject Rights

Applicants and employees may exercise your data subject rights by contacting Legal@ESS.com, by calling (844) 482-0300, or by clicking here. You may also authorize an agent to make a data subject request on your behalf, and the authorized agent may do so via the above-listed submission methods.

B2B contacts may exercise your data subject rights by contacting Legal@ESS.com, by calling (844) 482-0300, or by clicking here. You may also authorize an agent to make a data subject request on your behalf, and the authorized agent may do so via the above-listed submission methods.

Verification of Data Subject Requests

We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, if you authorize an agent to make a request on your behalf, we may require the agent to provide proof of signed permission from you to submit the request, or we may require you to verify your own identity to us or confirm with us that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under the CCPA. We will respond to your request consistent with applicable law.

Personal Information of Minors

Our online content is not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years, except as required by applicable law. If you believe that a child has submitted Personal Information to us, please email us at Legal@ESS.com or call us at (844) 482-0300 and we will delete the information.

Additional California Privacy Rights

Shine the Light Requests

California Civil Code Section § 1798.83 permits users of our website who are California residents to request information about our disclosure of Personal Information to other parties for their direct marketing purposes. To make such a request, please send an email to Legal@ESS.com with the subject “Shine the Light Request.”

Changes to this California Privacy Notice

We reserve the right to amend this California Privacy Notice at our discretion and at any time. When we make material changes to this California Privacy Notice, we will notify you by posting an updated California Privacy Notice on our website and listing the effective date of such updates.

Contact Us

If you have any questions regarding this California Privacy Notice or ESS’ collection and use of your Personal Information, or would like to exercise your data subject rights, you may do so by calling (844) 482-0300 or by emailing Legal@ESS.com.