Worklution Inc. California Privacy Notice

 

Date of Last Revision: October 5, 2024

 

  

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS 

This California Consumer Privacy Act Disclosure (“Disclosure”) explains how Worklution, Inc. (“Worklution”, “our”, “us” or “we”) collects, uses, discloses, shares, and retains Personal Information subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).  

This Disclosure applies solely to California residents and covers both online and offline practices (e.g., phone and in-person). 

WHAT IS PERSONAL INFORMATION?  

Under the CCPA, “Personal Information” is information that identifies, relates to, describes, or could reasonably be linked with a particular California resident or household. The CCPA, however, does not apply to certain information, such as information subject to the Health Insurance Portability and Accountability Act (HIPAA) and/or other federal and state law, such laws will govern and such activities and information are outside the scope of this Privacy Notice. 

OUR INFORMATION PRACTICES REGARDING PERSONAL INFORMATION 

We collect, use, disclose, share, and retain Personal Information relating to California residents in a variety of contexts, as described below. For example, we collect Personal Information relating to California residents for marketing purposes and from individuals who apply for employment with us or are our employees, vendors, contractors, or similar personnel. The specific Personal Information that we collect, use, disclose, share, and retain, relating to a California resident, will depend on our specific relationship or interaction with that individual. 

In the past twelve months, we have collected the following categories of Personal Information relating to California residents: 

  1. Personal identifiers, such as name and mailing address; 

  1. Personal Information, such as contact information and financial information; 

  1. Characteristics of protected classifications under California or federal law, such as age, gender, sexual orientation, religion, immigration status, and citizenship; 

  1. Commercial information, such as transaction and account information; 

  1. Internet or electronic network activity information, such as browsing history and interactions with our website; 

  1. Sensory data, such as call recordings, audio, electronic, visual, and similar information; 

  1. Professional or employment-related information, such as current employment information or employment history; 

  1. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics; and 

  1. Sensitive Personal Information, such as certain Account log-in, financial account, debit or credit card number, and the means to access the account (security or access code, password, credentials, etc.); precise geo-location information; racial or ethnic origin, religious or philosophical beliefs, or union membership; medical or mental health, a mental or physical health condition or diagnosis, sex life, or sexual orientation; genetic or biometric data that may be processed for the purpose of uniquely identifying an individual; citizenship or immigration status; contents of your mail, email, or text messages (where Worklution is not the intended recipient of the communication); and/or Personal Information collected from a known child under 13 years of age. 

We may keep Personal Information as long as necessary or relevant for the practices described in this Disclosure or as otherwise required by law.  Actual retention periods vary depending on product and service.  We use the following to determine retention periods: Personal Information that is needed to provide our products and services as described in this Disclosure, for auditing purposes, to troubleshoot problems or assist with investigations, to enforce our policies and to comply with legal requirements. Laws and regulations require all financial institutions to obtain, verify, and record information that identifies each person for whom we open or have established an account. 

In the past twelve months, we have collected the categories of Personal Information set forth above from the following categories of sources: 

  1. Directly from you; 

  1. Online and mobile app services, including cookies, pixel tags, beacons, and software development kits; 

  1. Government entities, including federal, state, or local government(s), or other public sources; 

  1. Third parties such as social networks and advertising networks; 

  1. Businesses or Non-businesses that you have authorized or directed to disclose your information to us; and 

  1. Service providers or contractors, with whom we have a contractual relationship to perform services on our behalf, or that you have authorized or directed to disclose your information with including data brokers as defined under California law. 

We may collect Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives. For example, we use the Personal Information we collect to: 

  1. Personalize, develop, market, advertise, and provide our products and services (including analytic services); 

  1. Provide customer service; 

  1. Process payments or transactions, provide financing, or fulfill orders; 

  1. Help to ensure security and integrity 

  1. Conduct research and data analysis; 

  1. Perform identity verification; 

  1. Maintain our systems, infrastructure, and facilities including debugging to identify and repair errors that impair existing intended functionality; 

  1. Maintain or service accounts; 

  1. Conduct risk and security control and monitoring; 

  1. Perform audit functions, including auditing interactions with consumers; 

  1. Maintain and enhance a product or service; and 

  1. Conduct other internal functions, such as investigations or research for technology development, comply with legal obligations, maintain business records, and exercise and defend legal claims and rights. 

We do not use or disclose Sensitive Personal Information for purposes other than as specified in CCPA. 

In the past twelve months, we have disclosed the following categories of Personal Information relating to California residents to the following categories for our business purposes, as indicated:  

  1. None 

Additionally, we have disclosed Personal Information to Business or Nonbusiness third parties based upon the consent or at the direction of a California resident to disclose the information. 

In the past twelve months, based upon our actual knowledge, we have not “sold” Personal Information or Sensitive Personal Information relating to California residents (including minors under 16 years of age).  For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a business or third party for monetary or other valuable consideration.  

YOUR RIGHTS UNDER THE CCPA 

If you are a California resident, you may have certain rights over the Personal Information we have about you.  You may request the following: 

  • The categories of Personal Information that we collected about you and the categories of sources from which we collected such information; 

  • The business or commercial purposes for collecting Personal Information about you; the categories of third parties to whom we disclosed such Personal Information (if applicable); the categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that category of Personal Information (if applicable); 

  • Access to specific pieces of Personal Information we collected about you; 

  • Deletion of Personal Information that we collected from you; 

  • Correction of Personal Information that may be inaccurate; 

  • Limitations regarding the use of your Sensitive Personal Information; and 

  • Opt-out of sharing Personal Information with third parties for targeted advertising purposes. 

In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer, where the Personal Information that we maintain about you is not subject to CCPA requirements, or where the Personal Information is a trade secret. We may also decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual.  

The CCPA also sets forth exceptions for when a business is not required to delete Personal Information, including but not limited to, where it is reasonably necessary to maintain Personal Information to provide a good or service that you requested, comply with a legal obligation, or to help ensure security and integrity.  As you would reasonably expect, the Sensitive Personal Information we collect, use, and disclose is done so to provide goods and services you requested, thus we cannot limit the use of your Sensitive Personal Information. 

Furthermore, we may decline the request to correct Personal Information depending on the nature of the Personal Information, the accuracy of the request, how the information was obtained and the business purposes for which the information was collected, maintained, or used. 

Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA. 

HOW TO MAKE A REQUEST 

If you are a California resident, you may submit a request by contacting us as set forth in the “Contact Us” section below.  Additionally, you may enable a tool at the browser or device level that automatically communicates your opt-out preferences, such as Global Privacy Control (“GPC”).  We will process the GPC signal as a request to opt-out for the browser or device you are using at that time; this may require separate opt-out on other browsers or devices that you use to visit our website. 

You may only exercise your rights to receive specific pieces of Personal Information twice within a 12-month period. The request must: 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information, or you are an authorized representative; and 

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

To respond to your request for access, correction, or deletion, we must verify your identity or authority to make the request and confirm the Personal Information in our systems relates to you or the person for whom you are authorized to make the request. We will use Personal Information provided by you, including your name, home address, email address, date of birth, last four digits of your Social Security number, and telephone number, for security purposes and to verify your identity to make the request.  We will provide you with an identification code via a one-time text message or one-time prerecorded voice message at the telephone number you provide. You will need to provide this identification code to us to continue with your request.  We use a third-party identity verification service to assist with ensuring that you are properly authenticated prior to fulfilling your request. 

If you intend to submit a request on behalf of someone else, we must have on file or you must provide to us sufficient documentation, such as an appropriate power of attorney, guardian, conservator or trustee or other such verification confirming you have the authority to act on behalf of the individual for whom you are submitting the request. To submit a request on behalf of someone else, please submit a request by contacting us as set forth in the “Contact Us” section below. 

CALIFORNIA "SHINE THE LIGHT" LAW 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by ting us as set forth in the “Contact Us” section below. 

CONTACT US 

If you have any questions or complaints about our Privacy Notice or information practices, would like to request a version of this notice in an accessible format, or would like to contact us in regards to any of the topics discussed above, please feel free to contact us at: (302) 291-2086, privacy@worklution.com; or Worklution, Inc., 16192 Coastal Hwy, Lewes, DE 19958 . 

 

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