WideOrbit CCPA Employee/Contractor Privacy Notice

WideOrbit values the trust of our employees and contractors and endeavors to protect the privacy of their personal information. The purpose of this California Consumer Privacy Act (“CCPA”) Employee/Contractor Privacy Notice is to notify California residents (“you”) of the processing of information that can reasonably be linked with them and that we collect, use, and disclose in the context of their current or former role as our employees or contractors (“Personal Information”).This Notice also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Notice and ensure that you have the right to provide their Personal Information to us.

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we collected and processed, as well as which categories of Personal Information we disclosed to third parties for our operational business and employment purposes, within the 12 months preceding the date this Notice was last updated.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, alias, postal address, unique personal identifiers, email address, account name, online identifiers, photo badges, beneficiary designations, and government-issued identifiers (e.g., Social Security number, driver’s license)	Our affiliates; service providers that provide services such as payroll, benefits, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Personal information as defined in the California customer records law, such as 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, medical information	Our affiliates; service providers that provide services such as payroll, benefits, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Protected class information under California or federal law, such as sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), age, race, color, national origin, disability, medical conditions, marital status, gender identity and expression, citizenship, immigration status, military/veteran status, domestic violence victim status, and request for leave	Our affiliates; service providers that provide services such as payroll, benefits, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Commercial information, such as transaction information and purchase history, including travel expenses, information about corporate credit card purchases, frequent flyer rewards, and other travel-related programs and expenses	Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Internet or network activity information, such as access and usage information regarding websites, applications, and systems, information about online communications, including browsing and search history, timestamp information, IP address, and access and activity logs	Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; ad networks; social networks; business partners; marketing partners
Geolocation data, such as device location, company-owned vehicle location, and approximate location derived from IP address	Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Audio/video data and similar information, such as call and video recordings, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage, photos on websites or in employee directories	Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; ad networks; social networks; business partners; marketing partners
Education information: confirmation of degree completion.	Our affiliates; service providers that provide services such as payroll, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Employment information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, information on internal investigations or disciplinary actions	Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, characteristics, predispositions, and abilities	Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; ad networks; social networks; business partners; marketing partners
Sensitive Personal Information. Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; financial account, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, citizenship, or immigration status	Our affiliates; service providers that provide services such as payroll, benefits, expense management, medical/health, IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not sell Personal Information, and we do not share or otherwise process Personal Information for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Notice was last updated. Without limiting the foregoing, we do not sell or share the Personal Information of minors under 16 years of age.

Sources of Personal Information

We collect Personal Information directly from you and from our affiliates, your colleagues and managers, references you provide, prior employers or schools, clients, background check providers, providers of employee benefits, social networks, publicly available databases, and cooperative databases.

Purposes for the Collection, Use, and Disclosure of Personal Information

We may collect, use, or disclose Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, and accomplishing our business purposes and objectives, including, for example, using Personal Information to:

Plan and manage workforce activities and personnel generally, including for recruitment, employee onboarding, appropriate staffing, performance management, training and career development, payments and benefit administration, employee training, leaves, and promotions;
Conduct workforce assessments, including determining physical or mental fitness for work and evaluating work performance;
Process payroll, manage wages and other awards such as stock options, stock grants and bonuses;
Reimburse expenses;
Provide healthcare, savings plans, and other benefits;
Operate, maintain, monitor, and secure our facilities, equipment, systems, networks, applications, and infrastructure;
Manage attendance, time keeping, leaves of absence, and vacation;
Facilitate employee communication and workforce travel;
Undertake quality and safety assurance measures, protect the health and safety of our workforce and others, and conduct risk and security control and monitoring;
Conduct research, analytics, and data analysis, such as to assist in succession planning and to ensure business continuity, as well as to design employee retention programs and diversity initiatives;
Perform identity verification, accounting, budgeting, audit, and other internal functions, such as internal investigations and disciplinary matters and handling grievances and terminations;
Operate and manage IT and communications systems and facilities, allocate company assets and human resources, and undertake strategic planning and project management; and
Comply with law, legal process, requests from governmental or regulatory authorities, internal policies and other requirements, such as income tax deductions, record-keeping, work permit and immigration regulations and reporting obligations, and the exercise or defense of legal claims.

Use and Disclosure of Sensitive Personal Information

We may use and disclose Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure, and the individuals with whom we interact. This includes, without limitation, establishing and maintaining your employment relationship with us, ensuring the diversity of our workforce, complying with legal obligations, managing payroll and corporate credit card use, administering and providing benefits, and securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure.

Retention Period

We retain Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The duration of your employment or contract with us;
The length of time we have an ongoing relationship with you or your dependents/beneficiaries and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your employment records for a certain period of time); and
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Individual Requests

You may, subject to applicable law, make the following requests:

You may request that we disclose to you the following information covering the 12 months preceding your request:
1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
2. The business or commercial purpose for collecting Personal Information about you; and
3. The categories of Personal Information about you that we disclosed and the categories of third parties to whom we disclosed such Personal Information.
You may request to correct inaccuracies in your Personal Information.
You may request that we delete your Personal Information we have collected from you.
You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including a copy of the Personal Information you provided to us in a portable format.

We will not unlawfully retaliate against you for making a request under the CCPA. To make a privacy request, please contact us at HR@wideorbit.com, or via telephone at 415-675-6700.We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as Date of Birth, Last 4 Digits of SSN, and Zip Code, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

We will verify and respond to your request consistent with applicable law.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted above. As part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

Changes to this Notice

We may change or update this Notice from time to time. When we do, we will communicate changes by posting the updated Notice on this page with a new “Last Updated” date.

Contact Us

Please contact HR@wideorbit.com if you have any questions regarding this Notice.

Last Reviewed and Updated: December 15, 2023