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California Information Sharing Disclosure

California law indicates that companies should disclose whether the following categories of information are collected, transferred for consideration, or transferred for an organization’s “business purpose” as that term is defined under California law.  We do not “sell” your personal information. Note that while a category may be marked that does not necessarily mean that we have information in that category about you.  For example, while we collect and transfer the Social Security Number of job applicants, we do not collect or transfer the Social Security Number of individuals that submit questions on our website’s “contact us” page. Please note that, in addition to those disclosures listed below, we may also disclose information when requested to government entities, auditors, lawyers, consultants, and other parties as required by law concerning any category (e.g., in response to a subpoena). The chart below describes our collection and disclosure practices when we collect personal information from Clients, Visitors of our Website, and job applicants. Please note that we may “share” Identifiers, Commercial Information, Internet and other electronic network activity, and Inferences for purposes of behavioral advertising.

Categories of Personal Information We Collect To Whom We Disclose Personal Information for a Business Purpose
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Government Identifiers – this may include social security number, driver’s license number, passport number or other similar identifiers.
  • Affiliates or subsidiaries
  • Business partners
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.
  • Affiliates or subsidiaries
  • Business partners
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.
  • Affiliates or subsidiaries
  • Business partners
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Professional or employment-related information
  • Affiliates or subsidiaries
  • Business partners
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
Non-public education information (as defined in the Family Educational Rights and Privacy Act)
  • Affiliates or subsidiaries
  • Business partners
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
Inferences drawn from any of the information listed above
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
  • Social networks

 

California also requires businesses to describe the “sensitive categories” of personal information they collect , the purposes of such collection and whether that information is sold or shared for cross-context behavioral advertising. Please see the table below for further information on how we treat these categories of information when we collect them from Clients, Visitors of our Website, and job applicants.

Categories of Sensitive Personal Information We Collect Purposes for which it is collected Is information sold or shared for the purpose of cross-context behavioral advertising
Social security, driver’s license, state identification card, or passport number If you apply for a position with us, we may collect this information to determine your eligibility to work. No
Racial or ethnic origin, religious or philosophical beliefs, or union membership.

Sex life or sexual orientation

If you apply for a position with us, and where required by law, we may use this information to comply with government reporting requirements. No
Health data If you apply to become a candidate through our recruiting services, we may collect this information where required for roles you are interested in. No