Privacy Policy

PRIVACY NOTICE FOR CALIFORNIA CONSUMERS ONLY

This PRIVACY NOTICE FOR CALIFORNIA CONSUMERS supplements the information contained in the Privacy Statement of the People Clariti family of companies (collectively, “we,” “us,” or “our”) and applies solely to California consumers (“consumers” or “you”), effective January 1, 2020. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. For purposes of this notice, a “third party” is an entity that is not a wholly-owned or majority-owned and controlled subsidiary of the VensureHR family of companies.

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 (“personal information”).

WE COLLECT THE FOLLOWING CATEGORIES OF PERSONAL INFORMATION AS INDICATED BELOW:

Identifiers

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.\

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)

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.

Protected classification characteristics under California or federal law

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, and genetic information (including familial genetic information).

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information

Genetic, physiological, behavioral, and biological characteristics or activity patterns are used to extract a template or other identifier or identifying information, such as fingerprints.

Internet or other similar network activity

Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data

Physical location or movements.

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Professional or employment-related information

Current or past job history or performance evaluations.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)

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.

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

PERSONAL INFORMATION DOES NOT INCLUDE:

Publicly available information from government records
De-identified or aggregated consumer information
Information excluded from the CCPA’s scope, like:

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.
Personal information is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), 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:

Directly from our clients, prospects, or employees. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients, prospects, or their employees. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website (www.vensure.com) or other portals. For example, from submissions through our website or website usage details collected automatically.
From third parties that interact with us in connection with the services we provide. For example, from government agencies when we verify data associated with payroll processing and withholding tax payments.

We may also collect personal information about you from other categories of sources, such as: our affiliates; our other clients; public and publicly available sources; our third-party referral partners, vendors, data suppliers, and service providers; partners with which we offer co-branded services or engage in joint event or marketing activities; social networks; news outlets and related media; and organizations with which you are employed or affiliated.

USE OF PERSONAL INFORMATION

WE MAY USE OR DISCLOSE THE PERSONAL INFORMATION WE COLLECT FOR ONE OR MORE OF THE FOLLOWING BUSINESS PURPOSES:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
To provide you with information, products, or services that you request from us.
To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
To operate, manage, and maintain our business.
To accomplish our business purposes and objectives.
To communicate with you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis, and service offering development.
For vendor management purposes.
As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information
held by us is among the assets transferred.

SHARING PERSONAL INFORMATION

WE DO NOT, AND WILL NOT, SELL YOUR PERSONAL INFORMATION.

We may share your personal information within People Clariti to provide services to you or in an effort to assess your needs and how we can help fulfill those needs.

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we require the recipient to keep that personal information confidential and secure, to not disclose that personal information to others, and to not use it for any purpose except performing the services related to the business purpose.

IN THE PRECEDING TWELVE (12) MONTHS, WE HAVE DISCLOSED THE FOLLOWING CATEGORIES OF PERSONAL INFORMATION FOR A BUSINESS