Privacy Policy
Effective 19th May 2021
This Privacy Policy (“Policy”) describes the ways Deserve, Inc. (referred herein as “we”, “us”, “our”) or our affiliates collect, protect, use and store your personal information. You accept this Privacy Policy by using our products and services (collectively “Services”) on our Website or through any other means. We may amend this Policy at any time by posting a revised version on our website (“the Site”). We will attempt to give a reasonable notice period upon making any changes; however, unless otherwise stated, the revised version will be effective at the time we post it. This Privacy Policy is incorporated into the Terms of Use by this reference.
By using our Services, you are consenting to our processing of your Personal Information and data as set forth in this Policy now and as amended. As used herein, “processing” means using or accessing information in any way, including but not limited to collecting, storing, deleting, combining, and disclosing information. Our servers are located in the United States. Accordingly, if you reside outside the U.S., by using the Services, you acknowledge and agree that your Personal Information will be transferred to the United States and processed and stored in the United States. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
Our Services contain links to other websites. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of every website you visit.
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: when you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.
The types of personal information we collect depends on the products and services you use. It may include:
If you desire to access certain parts of the Services, you will be required to become a registered user and to submit certain Personal Information to Deserve.com. Personal Information that we may collect in such instances may include your full name, email address, mailing address, telephone number, date of birth and other information that you provide us with as part of the credit card application. Additionally, we may request that you upload a copy of your official passport/national identity card, a copy of your financial statement issued by a US bank, and/or a copy of your US I-20 Form and US Student Visa which are issued by the U.S. Department of Homeland Security in order to verify your identity, program eligibility, and ability to repay debt. We may also ask our users to generate a new personal identification number (PIN) or password to access our Services. In general, we may use any information provided by you to verify your identity or as part of a credit application or other business processes.
Information Deserve Learns From Your Use of our Services or Access of the Site When you visit the Deserve website or use the Services, we may collect information from your computer, mobile phone, or similar device. This information may include your IP address and device information including but not limited to identifier, device name and type, operating system, location, mobile network information, and standard web log information such as your browser type, traffic to and from our website, the pages you accessed on our website, and any other available information. We may also collect information about your use and interaction with our website, application, or Services. For example, we may evaluate your computer, mobile phone, or other access device for indicators of fraud, or analyze your website clicks to assess your interest in our specific product terms. When you use our Services, we may also store information based on your usage history. This includes but is not limited to details of your purchases, content you viewed, event information, referring sites or click stream information, and web “cookies” or “tokens” that may uniquely identify your browser, device, or your account. We may also collect information about you from any contact you have with any of our employees, our customer support team, or through surveys, or through interactions with our agents and/or affiliates.
Deserve.com may receive varying degrees of location information from Social Media Services (as defined below) that you enable within our Service and also (with your permission) from your computing devices (“Location Data”). For example, we may collect and use location data (e.g., GPS or IP-based geography detection) to screen for fraudulent activity or to verify self- reported information (for example, to verify you reside in a certain city or near a university in which you are enrolled) and to customize the Service to make it more relevant to you (for example, to send newsletter information that may be of interest to you).
When you interact with the Site or use our Services, our servers automatically receive and store certain personally non-identifiable information (“Log Data”). This Log Data is collected passively and may include (but is not limited to) information such as your IP address, browser type, mobile phone type, software settings/configurations, or the domain from which you are visiting, the Site pages you visit, the search terms you use, and any advertisements on which you click. We use Log Data and analytics-based observations to provide you with the Services (for example, to send an SMS to your mobile device) and we may pool Log Data with other information to monitor the use of the Services, and for the technical administration of the Services. If we are asked to comply with a subpoena or other legal demand or where we suspect that there has been a violation of our policies, then we will associate your IP address with any other Personal Information to identify you personally, according to our Terms of Use and/or applicable laws.
Like many websites and services, we also may use “cookie” technology to collect additional Site usage data and to improve the Site and Services and related offers. A cookie is a small data file that we transfer to your computer’s hard disk. Deserve may use both session cookies and persistent cookies (known as “persistent tokens”) to better understand how you interact with the Site and our Services, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our Services. A session cookie or security token enables certain features of the Site and Services and is often (but not always) deleted from your computer when you disconnect from or leave the Site. A persistent token will likely remain after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent tokens can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
We may, or our Partners or Affiliates may, also deliver a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks (and other websites) to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to send targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their sites.
Deserve or its Partners or Affiliates may collect payment information such as a valid credit card number, type, and expiration date, or other financial information such as a routing & account number for check payments. Payment information is collected and stored by our third-party payment processing company (the “Payment Processor”) and such use and storage of the information is governed by the Payment Processor’s
applicable Terms of Use and Privacy Policy. Our payment processor is CoreCard (www.corecard.com).
Prior to establishing a Deserve account or after a Deserve account is established, or both, we invite Deserve account holders enter certain login credentials (such as a username and password) for certain online account types (for example, credit cards, debit cards, or traditional bank accounts) in order to verify identity. These credentials provide Deserve with consistent and reliable access to each financial account. Deserve uses such access to monitor and assess account holder’s ability to repay debt or counter fraud.
If you allow Deserve to access the contacts/address book on your phone or other services (such as email) through the permission system used by your mobile platform, Deserve may access and store names and other contact information from your address book to facilitate social interactions through our Services and execute our referral program. Access to contacts may be requested as part of a customer referral program or validation of self-reported information.
We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, locations, distance traveled, and other related transaction details. Additionally, if someone uses your customer referral code, then we may associate your name with that person.
In an ongoing effort to better understand and serve the users of the Services, Deserve often conducts research on our customer demographics, interests, and behavior based on the information provided to us. This research may be compiled and analyzed on an aggregate basis and Deserve may share this aggregated data with our marketing affiliates, agents, and business partners. This aggregated information does not identify you personally. Deserve may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.
We may obtain information about you from third parties such as credit bureaus, the U.S. Department of Homeland Security, student enrollment verification services, and identity verification services. You may choose to provide us with access to certain personal information stored by third parties such as social media websites and services (“Social Media Services”) or banking websites. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your Deserve account and authorizing Deserve to have access to this information, you agree that Deserve may collect, store, and use this information in accordance with this Policy.
We collect information regarding how you and other site visitors use and interact with our Services, including preferences expressed, and settings chosen. In some cases, we do
this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
Deserve stores and processes your information while maintaining physical, electronic, and procedural safeguards of its Site and Systems. We maintain physical security measures to guard against unauthorized access to systems and use electronic safeguards such as firewalls and data encryption. We authorize access to personal information only for those authorized employees with a business need to have access to personal information.
Deserve uses the Personal Information you provide in a manner that is consistent with this Policy. We may use your information, including non-public personal information as follows:
To provide, maintain, and improve our Services; To provide inputs to our credit underwriting system and to assess creditworthiness of credit card applicants; To provide and deliver the products and services you request, process transactions and send you related information, including confirmations; To verify your identity and prevent fraud or unauthorized access; Send you technical notices, updates, security alerts and support and administrative messages; To respond to your comments, questions, and requests, and provide customer service; To communicate with you about products, services, offers, promotions, incentives, and events offered by Deserve and others, and provide news and information we think will be of interest to you; To monitor and analyze trends, usage, and activities in connection with our Services; To comply with legal obligations; To personalize and improve the Services and provide advertisements, content, or features that match user profiles or interests; To process and deliver contest or promotion entries and incentives; To link or combine it with the information we receive from others to help understand your needs and provide you with better service; and to carry out any other purpose for which the information was collected.
If you contact us by email, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you and provide you with information about our products and services and the products and services of our partners that we believe may be of interest to you. If you decide at any time that you no longer wish to receive such marketing information or communications from us, please follow the unsubscribe instructions provided in any of our communications.
In an ongoing effort to better understand and serve the users of our Services, Deserve occasionally conducts separate research efforts on its customer demographics, interests, and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed in the aggregate and Deserve may share this aggregated data with its affiliates, agents and business partners. This aggregated information does not identify you personally. Deserve may also disclose aggregate user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
At times Deserve may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help Deserve market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. Personal information will never be shared with third parties for their marketing purposes.
We consider your information to be a vital part of Deserve’s relationship with you and, accordingly, we do not share it unnecessarily. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as outlined below.
Deserve shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Deserve operates.
If we collect credit card information for payments, or other financial information related to payments, then that information will be collected and stored by our Payment Processor. We will from time to time request and receive your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, assessing credit risk, processing invitations to apply for increased credit limits, or enrolling you in such other programs in which you elect to participate, identifying or researching possible fraudulent transactions, and otherwise as needed to manage our business.
You can choose to access certain third party communication tools or Social Media Services through our Services When you choose to do so, you will be sharing information with those Social Media Services, and the information you share will be governed by their privacy policies and Terms of Use. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to third parties such as Deserve. When you add Social Media Service accounts to the Service or log into the Service using your Social Media Services account, we will collect relevant information necessary to enable our Services and access that Social Media Service. In all cases, you will provide your login information, such as your username and password, directly to the Social Media Service and not to Deserve. As part of such integration, the Social Media Service will provide Deserve with access to certain information that you have provided to the Social Media Service, and Deserve will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of such third parties and Deserve shall have no liability or responsibility for the privacy practices or actions of any Social Media Services that may be enabled with or accessed through the Service.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Deserve to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
We do not sell or rent your personal information to third parties.
If you no longer wish to receive notifications (such as SMS or email messages) about our Services, you may change your notification preferences by emailing [email protected]. Alternatively, you may be able to indicate your preference by logging into your Deserve account and adjusting your preferences or by following the directions provided with the communication. Deserve reserves the right to close your account should you opt out of the critical notices that are required to perform our Services.
You can review and edit your personal information at any time by logging in to your account on Deserve’s Website or by contacting us at [email protected]. You can also request to close your account with Deserve by contacting us at 1.800.418.2362. If you close your Deserve account, we will mark your account in our database as “Closed,” but will keep your account information in our database to comply with our legal obligations. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or in accordance with this Privacy Policy.
This Privacy Policy may not constitute your entire set of privacy rights, as these may vary from state to state. For example, California Civil Code Section § 1798.100 permits California residents who are users of the Deserve site to request certain information regarding the disclosure of personal information to third parties for direct marketing
purposes. To make such a request, please send an email to [email protected]. To be certain of your privacy rights, you may wish to contact the agency in your state that is charged with overseeing consumer privacy rights.
The aim of the GDPR is to protect the “personal data” of EU citizens – including how their personal data is collected, stored, processed and destroyed. The meaning of “personal data” under the GDPR currently exceeds how similar terms are defined in the U.S. Deserve, Inc. accepts and reviews all applicants for credit. This should be in the Cardholder Agreement as that covers the issuance of the credit card.
Deserve may update its Privacy Policy from time to time. When we change the Policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. We will also contact you via your contact information on file, for example by email, notification or some other equivalent method. If you have questions or concerns regarding this Privacy and Security Policy, please contact us at [email protected] or call 1.800.418.2362.
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the U.S. Online Privacy Notice of Deserve and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to 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 other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect 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, we have collected the following categories of personal information from consumers within the last twelve (12) months:
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
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.
YES
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
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
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
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
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
Audio, electronic, visual, thermal, olfactory, or similar information.
YES
Current or past job history or performance evaluations.
YES
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.
NO
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
Personal information does not include:
o 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;
o 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.
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose the personal information we collect for one or more of the following business purposes:
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.
We 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. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
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 F: Internet or other similar network activity Category
G: Geolocation data Category
I: Employment related information
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold any personal information.
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 we 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, we will disclose to you:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
US Postal Mail to:
Deserve, Inc
Attn: Privacy
PO Box 57780
Murray, UT 84157; or
Email us at [email protected]
Call us at 1.800.418.2362
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 12- month period. The verifiable consumer request must:
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.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), 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:
We reserve 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 our Website and update the notice’s effective date. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. We will also contact you via your contact information on file, for example by email, notification or some other equivalent method. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1.800.418.2362
Website: deserve.com
Email: [email protected]
Postal Address: Deserve, Inc
Attn: Privacy
PO Box 57780, Murray, UT 84157
Updated 6/30/2023
This Notice to California Employees and Job Applicants (“Notice”) of Deserve Inc. applies to offline and online data collection practices when you submit personal data for the purposes of applying for and/or becoming an employee of Deserve, Inc., and during the course of your employment with Deserve Inc., pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this policy does not legally apply to you, though you may have similar rights afforded to you via other Organizational policies or processes.
The information that you provide to Deserve (sometimes referred to as “we”, “us” or “our”) is collected and used in order for us to consider you for employment, retain you as an employee, coordinate and/or provide benefits to you, and to maintain employment records.
Please note that if you are visiting our website in a non-employment context, any of your personal information collected in that capacity is subject to our consumer Privacy Policy. For more information, please review the Privacy Policy and California Notice on our website.
We collect personal information from you when you choose to voluntarily provide it for purposes of employment with or when applying for employment with us. We may collect Personal Information such as your name, job title, mailing address, right to work for I-9 verification, phone number, date of birth, gender, names and relationships of dependents, emergency contact information, credit check information, background check information, your resume (with professional, employment and educational background information), language proficiency, voice recording, beneficiary designations, proof of identification, doctor’s notes, diversity and EEO data collection and any other information you provide to us.
We collect Sensitive Personal Information such as your social security number, driver’s license number, passport information, and/or state ID card numbers; banking information; diversity and EEO data collection including race and ethnicity, sexual orientation, military and disability status. We collect information about you through your browser, computer hardware and software when you access company hosted applications, our network or use devices provided by us. This information can include your IP address, device ID, browser type, domain names, access times and dates, pages viewed, one or more cookies that may uniquely identify your browser, referring website addresses, what applications are run on your company issued device, files downloaded, opened, and created using company managed equipment, geolocation of laptops and mobile devices which contain company data, and any personal information entered into any company controlled system, including company email.
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
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.
YES
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
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
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
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
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
Audio, electronic, visual, thermal, olfactory, or similar information.
YES
Current or past job history or performance evaluations.
YES
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.
NO
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
We use Personal Information of employees and job applicants for a wide range of purposes, including:
We disclose Personal Information you provide to consultants, service providers, service partners, and contractors that we use to support our business and operations who have agreed to keep the information confidential.
We may disclose Personal Information to outside parties, including governmental agencies, if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions or investigations.
We may disclose Personal Information to non-parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.
We have not sold or shared personal information about California employees or job applicants in the past 12 months. This statement is based specifically on how the terms sale/sold and share/sharing/shared are defined by the CCPA.
We have disclosed the following categories of personal information about California employees and job applicants for a business purpose in the preceding 12 months:
We will retain your Personal Information for as long as it is necessary for the purposes described in this notice and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and comply with our internal retention policies.
Under California law, as an employee or applicant residing in California you are afforded several rights regarding the personal information collected about you. However, there are several exceptions that may apply. Exceptions may include our right to maintain personal information of employees for business purposes and solely internal uses reasonably aligned with the expectations of the employee, as well as to comply with any legal obligations, including maintaining proper employee records, or maintaining privilege or confidentiality of certain records, in compliance with applicable U.S. and California labor laws and other legal 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 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 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 in a readily usable format to allow for data portability..
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
Sensitive personal and financial identifiers (such as social security number, bank account numbers, payroll information, etc.) will not be provided in response to a request, but we will let you know if we have those identifiers and information on file.
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 applicable service providers to delete) your personal information from our records, unless a valid exception applies.
You have the right to request that we correct inaccurate information about you. There may be cases where you are able to update or correct the information yourself within the application within which the data resides and we will be happy to provide you with guidance on how to make applicable changes should you wish to do so.
You have the right to opt out of the sale or sharing of information. We do not sell or share your information, as defined within the CCPA.
We do not use SPI for purposes other than those allowed by the CCPA and its regulations
You have a right to non-discrimination when exercising any of the above rights afforded to you by the CCPA. We will not retaliate against you for exercising any of the above rights.
To exercise the rights described above, please submit a verifiable consumer request to us by:
Emailing us at [email protected]
Sending your request via US Postal Mail to:
Only you or an authorized person or entity that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may only make a verifiable request for access twice within a 12- month period. The verifiable 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 request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable request within 45 days of its receipt and will provide you with a notice of receipt within 10 days of receiving your request. If we require more time (up to 90 days) we will inform you of the reason and extension period in writing. We will deliver our written response to the current address on file or the email address used to submit the request. Any disclosures we provide may only cover the time period of January 1, 2022 to the present. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For access 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 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.
This Notice may be revised from time to time. If this Notice changes in a material way, we will notify employees of such changes by posting the revised policy and notifying them via company email. Applicants should check the link to the notice within job descriptions from time to time and whenever submitting information to us.
For information and questions about the use of your personal information, this Notice or your rights under California law, you may contact us via email at [email protected] or via mail at: