California Applicant & Employee Privacy Notice
Effective Date: January 1, 2023
This Notice describes the categories of personal information we collect and the purposes for which we process that information in connection with your application or employment with Numotion. We are providing this Notice in accordance with the California Consumer Privacy Rights Act (CPRA) for any applicants or employees residing in California.
How Numotion Collects, Discloses and Retains Your Data
We have set out below the categories of personal information we may have collected about California residents in the preceding twelve (12) months and, for each category of personal information that may have been collected, the categories of sources from which that information may have been collected, and the categories of third parties as defined under the CPRA with whom we may have disclosed the personal information.
We May Disclose Any of the Personal Information We Collect as Follows:
Disclosing for Legal Purposes:
|Category of Personal Information
||We may have collected such personal information from the following categories of sources:
||We may have disclosed such personal information with the following categories of third parties:
|Identifiers and Contact Information: e.g., names, addresses, telephone numbers, mobile numbers, email addresses, dates of birth, Social Security
numbers, driver’s license or state
identification numbers, bank account information, dependent and beneficiary information (names, dates of birth, Social
Security numbers) and other similar contact information and identifiers.
- Directly from you, e.g., from forms you completed.
- Indirectly from you, e.g., information you authorized a third-party or service provider to provide to us.
- From service providers that interacted with us in connection with the services performed (e.g., background screening and verification including education, past employment, criminal background, references).
- From software and IT systems we use as part of our operations (e.g., Microsoft Office, mobile device management, vehicle fleet management)
- From a public source (i.e., the internet or public records).
- Third-party human resources and information technology vendors
- Public entities and institutions (e.g., regulatory, quasi-regulatory, tax or other authorities, law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies)
- Professional advisors including law firms, accountants, auditors, insurers, and tax advisors.
|Characteristics of protected classifications under California or federal law: e.g., sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status; veteran or military status.
Internet or other electronic network activity information. This includes without limitation:
- all activity on Numotion’s information systems, such as internet browsing history activity, search history, use of workflow systems such as Venu and Salesforce, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords
- all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an Employee’s use of Numotion-issued devices
|Geolocation data. This includes
IP address for Numotion website visitors and GPS location data from Numotion-issued devices, personal devices used for Numotion business with mobile device management software installed, and vehicles used for Numotion business.
Professional and employment-related information. This includes without limitation:
- data submitted with employment applications including, employment history, employment recommendations, etc.
- background check and credentialing data;
- work authorization
- professional licenses
- vaccination and health data
- educational degrees
- fitness for duty data and reports (upon return from a medical leave of absence)
- performance and disciplinary records
- salary and bonus data
- benefit plan enrollment, participation, and claims information
- leave of absence information including religious and family obligations, physical and mental health data concerning employee and his or her family members
|Education information. This category includes education history.
|Inferences drawn from the personal information in the categories above. Note that we do not use or disclose sensitive personal information for purposes other than those specified in section 7027, subsection (m).
We may disclose personal information with third parties in order to: (a) comply with a legal process or a regulatory investigation (e.g., a subpoena, court order or required regulatory disclosure); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with our business partners, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our business partners, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Disclosing In the Event of a Corporate Transaction:
We may also disclose personal information in the event of a corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, for purposes of due diligence connected with any such transaction or transition of service to another provider. In such cases, your personal information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Disclosing to Service Providers:
We disclose personal information we collect with our service providers, which may include (for instance) providers involved in technical or customer support, operations including payroll, benefits and/or pension, insurance, travel, background screening, search firms who submit candidate information to us, recruiting, web or data hosting, billing, accounting, auditing, legal consultancy, security, marketing, or otherwise assisting us to provide, develop, maintain, and improve our company and our services.
For Which Business Purposes Numotion Collects, Uses and Retains Your Data
We may collect, use and retain your personal information for one or more of the following business purposes:
Retention of Personal Information
- To evaluate applications for employment or internal promotion.
- To attract, maintain, motivate, and administer the employment relationship of Numotion employees, including, but not limited to the following: recruitment and staffing, creating and maintaining an employee contact directory, compensation and payroll, succession planning and management, reorganization, performance assessment, promotion and career management, administering bonus, award and recognition programs, administering employee enrollment and participation in activities and programs offered to eligible employees, training and development, employee benefits administration, pension plan administration, 401k and/or retirement plans, health insurance benefits, business travel and expenses, relocating and transferring employees, compliance with applicable legal and regulatory requirements, and communication with applicants and employees.
- To comply with regulatory and legal obligations such as (i) fulfilling control and reporting obligations under applicable financial regulations, including securities regulations; (ii) complying with investor protection or conduct of business regulation (such as carrying out suitability or appropriateness assessments; (iii) comply with state and federal law requiring employers to maintain certain records.
- Other internal purposes, for example authorizing, granting, administering, monitoring, and terminating access to or use of company systems, software, facilities, records, property, and infrastructure.
- To protect the company, its employees, and the public against injury, theft, legal liability, fraud or abuse, internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.
- To provide you with information, products, or services that you request from us.
- As necessary or appropriate to protect the rights, property, or safety of us, our customers, or others
Personal information will not be kept for longer than is necessary for the business purpose for which it is collected and processed. In certain cases, laws or regulations require us to keep records for specific periods of time, including following termination of the employment relationship. In other cases, records are retained in order to administer the employment relationship or to resolve queries or disputes which arise from time to time.
No Sale of Personal Information
We do not and will not sell California residents’ personal information or share it for cross-contextual marketing purposes.
Your California Rights and Choices
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.
a. Right to Opt-Out of the Sale of Your Personal Information.
California residents may opt-out of the sale of their personal information. We do not, and will not, sell your personal information. Nor do we share your personal information for cross-contextual marketing purposes.
b. Right to Request Deletion of Your Personal Information
You may also request that we delete any personal information that we have collected directly from you. However, we may retain personal information for certain important purposes, such as (a) to comply with legal obligations such as record keeping requirements under other laws, (b) to protect our business, systems, and users from fraudulent activity, (c) to address technical issues that impair existing functionality (such as de-bugging purposes), (d) as necessary for us, or others, to exercise their free speech or other rights, (e) to comply with law enforcement requests pursuant to lawful process, (f) for scientific or historical research, (g) for our own internal purposes reasonably related to your relationship with us, or (f) as needed to exercise or defend legal claims.
c. Right to Request Access to Your Personal Information
California residents also have the right to request that we disclose what categories of your personal information we collect, use, or sell. As a California resident, you may request access to the specific pieces of personal information that we have collected from you.
California residents may learn more how to exercise these rights of information access by sending an email to email@example.com, submitting a request through our online webform at https://www.numotion.com/personal-information-request-form
or by calling toll free at (833) 998-2027. We will only use the information you submit to respond to your request, and we may need to identify you and your state of residence before we can respond.
However, we may withhold some personal information where the risk to you or our business is too great to disclose the information, or where we cannot verify your identity in relation to such personal information. Thus, for security purposes (and as required under California law), we will verify your identity – partly by requesting certain information from you – when you request to exercise certain of your California privacy rights.
Once we have verified your identity, we will respond to your request as appropriate:
Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CPRA and provided we do not believe there is an overriding privacy or security concern by doing so.
If we are unable to complete your requests fully for any of the reasons above, we will provide you with additional information about the reasons why we could not comply with your request.
d. Right to Nondiscrimination.
We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
e. Information About Persons Under 16 Years of Age
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
f. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CPRA as described above. We will take steps to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf by providing us with a signed written authorization or a copy of a power of attorney.
If you have questions about Numotion’s privacy policies and procedures or rights you may have concerning your personal information, you may contact Numotion’s Privacy Officer at firstname.lastname@example.org.