Effective date: January 1, 2020
SOFIE Co. including its affiliates and subsidiaries (“SOFIE,” “we,” “us,” or “our”) provides this Privacy Notice for California Consumers (Employees) (the “CCPA Employee Privacy Notice”) to you to notify you of our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA Employee Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). We provide you this notice because under the CCPA, California Residents who are employees, employee applicants, or contractors qualify as Consumers. For purposes of this CCPA Employee Privacy Notice, when we refer to Consumers, we mean you to the extent you are a California employee, employee applicant, or contractor.
Information We Collect
We may collect Personal Information from you in a variety of different situations, including, but not limited to, on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. More specifically, SOFIE collects the following categories of Personal Information from its California applicants, employees, and contractors, which will depend on the particular Business Purpose for which we collect it:
|Category||Examples of Personal Information Collected|
|A. Identifiers.||A real name, alias, postal address, telephone number, mobile device ID, Internet Protocol address, email address, Social Security number, driver’s license number, passport number.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, 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, or health insurance information.|
|C. Protected classification characteristics under California or federal law.||Age, race, citizenship, marital status, medical condition, physical or mental disability, sex, veteran or military status, genetic information.|
|D. Commercial information.||None.|
|E. Biometric information.||None.|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
|H. Sensory data.||Electronic, audio, and visual information.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations, employee background check.|
|J. Education information, as defined by the Family Educational Rights and Privacy Act||None.|
|K. Inferences drawn from other personal information.||None.|
Personal information does not include deidentified or aggregated consumer information.
SOFIE obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete.
- Indirectly from you. For example, from observing your actions on our website, our Intranet, or from information your computer or mobile device transmits when interacting with our website or intranet.
- Consumer reporting agencies relating to employee background checks.
How We Use Personal Information
We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:
- To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job or become an employee, we will use that personal information in connection with your employment or employment application.
- To contact you and to inform you about benefits or information relating to your employment or employment application.
- To provide, support, personalize, and develop our website and services relating to your employment or employment application.
- To create, maintain, customize, and secure your information or account with us.
- To process your requests or transactions and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our systems, Website, services, databases, and other technology assets, and business.
- For research, analysis, and business development, including to develop and improve our business processes, Website, and services.
- 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 subsequently agreed to by you.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SOFIE assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SOFIE about our Consumers is among the assets transferred.
How We Share Personal Information
SOFIE may disclose your Personal Information to a third party for a business purpose, including to our service providers.
We share your personal information with the following categories of third parties:
- Service providers.
- Third parties with whom you direct us to share your personal information, including consumer reporting agencies, to conduct employment background checks.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, SOFIE has disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Third parties with whom you direct us to share your personal information, including consumer reporting agencies to conduct employment background checks.
Other California Privacy Rights
We do not disclose your Personal Information relating to you being an employee applicant, employee, or contractor with SOFIE to third parties for their direct marketing purposes. We do not share such Personal Information with third parties for their direct marketing purposes.
Changes to Our CCPA Employee Privacy Notice
SOFIE reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on firstname.lastname@example.org and update the notice’s Effective Date above.
If you have any questions or comments about this notice, the ways in which SOFIE collects and uses your information described above, please do not hesitate to contact us at:
ATTN: Privacy Team
21000 Atlantic Blvd. Suite 730
Dulles, VA 20166