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California Employment and Independent Contractor Privacy Notice

This California Employment and Independent Contractor Privacy Notice applies to California residents and tells you how StrategyBRIX collects, uses, shares, discloses, and retains (collectively “processes”) your personal information. We are committed to processing your personal information responsibly and in accordance with applicable laws and internal policies. For the purpose of this California-specific Privacy Notice, residents include individuals who: 1) have applied or may apply for a position at StrategyBRIX; 2) are current or former StrategyBRIX team members; 3) are beneficiaries or emergency contacts of a current or former team member; 4) receive insurance or other benefits through a StrategyBRIX team member; or 5) are independent contractors performing services at StrategyBRIX (collectively, “HR Covered Individuals”). If you provide personal information of another person (e.g., beneficiary or emergency contact), then you are responsible for providing this Privacy Notice to that individual.

Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act. 

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Notice of Collection and Use of Personal Information

As a part of employment or contractor-related activities, we may need to collect and use your personal information to establish, manage, terminate, or otherwise administer the relationship. Your personal information may also be used for purposes of internal administration and compliance with legal and regulatory obligations.  Details below apply to current processing as well as the 12-month period prior to the date this Privacy Notice was last updated. 
 

Categories of Personal Information Collected

StrategyBRIX may collect the following categories of personal information about HR Covered Individuals.

  • Identifiers (e.g., email address, mailing address, name, phone number, social security number, state identification, team member number)

  • Characteristics of protected classifications (e.g., age, disability, gender, marital status, military status, race, sexual orientation)

  • Commercial information (e.g., products or services purchased)

  • Biometric information (e.g., face geometry, fingerprint, voice recording)

  • Internet or other electronic network activity (e.g., browse history, information regarding your interaction with websites or applications)

  • Geolocation data (e.g., device location, VPN location)

  • Audio, electronic, or visual information (e.g., phone calls, photos, video)

  • Professional or employment-related information (e.g., benefits, compensation, medical related information, performance reviews, training)

  • Education information (e.g., degree, educational institution)

  • Inferences drawn from information above (e.g., preferences or characteristics related to a position at StrategyBRIX)
     

Purposes for Collecting Personal Information

StrategyBRIX may use personal information of HR Covered Individuals for the purposes described below.

  • Determine eligibility for initial employment, including the verification of references and qualifications 

  • Establish, manage, terminate or otherwise administer the employment relationship

  • Administer pay and benefits (e.g., benefit plan, payroll, team member discounts)

  • Process employee work-related claims (e.g., workers’ compensation or insurance claims)

  • Provide training, development, and promotion opportunities

  • Conduct performance reviews and determine performance requirements

  • Assess qualifications for a particular job or task

  • Establish a point of contact in the event of an emergency (e.g., next of kin)

  • Comply with applicable labor and employment statutes

  • Compile directories and telephone lists

  • Make the necessary applications to obtain visas or other permits for work-related travel

  • Allow access to mobile applications through your own device

  • Ensure compliance with StrategyBRIX’s requirements, policies and procedures

  • Ensure the security of company-held information

  • Conduct investigations

  • Assist law enforcement and respond to legal/regulatory inquiries

  • Fulfill and manage orders and purchases

  • Enable volunteer activities and civic engagement

  • Conduct research and analysis, including focus groups and surveys

  • Support diversity and inclusion initiatives

  • Fulfill such other business purposes as reasonably determined by StrategyBRIX

StrategyBRIX does not process sensitive personal information with the purpose of inferring characteristics about HR Covered Individuals. 


To the extent we process de-identified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information for the time period required or permitted by law or for the time reasonably necessary to achieve the purposes described in this Privacy Notice or any other notice provided at the time of collection. Retention is based on several factors, including legal requirements, statutes of limitation, and business needs.
 

Sources of Personal Information

StrategyBRIX may obtain personal information about HR Covered Individuals from the following categories of sources:

  • Directly from you

  • Your device(s)

  • Other individuals, for example, in connection with hiring referrals, provision of benefits, feedback from guests or business partners

  • Our affiliates and subsidiaries

  • Service providers, contractors, and other vendors who provide services on our behalf; 

  • Internet service providers

  • Operating systems and platforms

  • Government entities

  • Social networks (e.g., LinkedIn, Indeed)

  • Data brokers (e.g., background check services)
     

Disclosure of Personal Information

StrategyBRIX may disclose the following categories of personal information about HR Covered Individuals to the following categories of third parties. Disclosure is for business purposes related to establishing or maintaining the employment relationship.


Categories of Personal Information

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  • Identifiers

  • Characteristics of protected classifications

  • Commercial information

  • Internet or other electronic network activity

  • Geolocation data

  • Audio, electronic, or visual information

  • Professional or employment-related information

  • Education information

  • Inferences drawn from information above

  • Biometric information

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Categories of Third Parties
 

  • Business partners, such as benefit administrators and training providers

  • Government entities, such as regulators or courts

  • Professional services organizations, such as auditors and law firms

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We may also share the information we collect with our service providers and within StrategyBRIX, which includes all StrategyBRIX subsidiaries and affiliates.

In addition to the categories of third parties identified above, we may disclose personal information about HR Covered Individuals to third parties in connection with corporate transactions.

StrategyBRIX does not share for cross-context behavioral advertising purposes or sell personal information about HR Covered Individuals. 

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California Privacy Rights
 

If you are an HR Covered Individual, you have the following rights:

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information or categories of personal information we have collected, used, disclosed, and sold or shared about you. ​

  • Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate. ​

  • Deletion: You have the right to request that we delete certain personal information we have collected from you.

    • Note: Certain personal information may not be deleted if subject to legal exceptions (e.g., legal compliance, ongoing employment)

 

How to Submit a Request: To submit an access, correction, or deletion request, please email jas@strategybrix.com.

 

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. Based on the type of HR Covered Individual request, you will be required to submit specific pieces of information.  StrategyBRIX will use this information to search our systems and determine if we have information about you.  If we can locate information about you, we will fulfill your request as required by law.

If you are an authorized agent, you will be required to submit your information as well as specific pieces of information about the individual for whom you are making a request. You will also be asked to fill out a certification form confirming your information and certifying you have the right to make this request on behalf of the individual.

Non-Discrimination: StrategyBRIX will not discriminate against you because you exercise your rights. For example, StrategyBRIX will not deny you employment if you make an access request.

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