PRIVACY NOTICE TO CALIFORNIA EMPLOYEES
Effective Date: August 3, 2022 (Version I)
Under the California Consumer Privacy Act of 2018 (the “CCPA”), Snapdocs, Inc. and its affiliates (collectively “Snapdocs”, “we”, “us” or “our”) are required to inform California residents who are job applicants, employees, owners, directors, officers, and contractors about the categories of personal information we collect about you and the purposes for which we use and disclose personal information.
This Privacy Notice to California Employees (this “Notice”) contains disclosures required by the CCPA and applies only to personal information that is subject to the CCPA. This Notice does not create or form part of any contract for employment or otherwise with Snapdocs. Any use of our services and personal information collected by use of www.snapdocs.com or our other websites is governed by our Employee Handbook, Terms of Service, and general Privacy Policy.
CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT
● “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
● “Other Personal Information” 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, credit card number, debit card number, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories;
● “Protected Characteristics” under California or federal law for classifications such as 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, or veteran or military status;
● “Internet or Network Activity” such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
● “Professional or Employment Related Information” such as current or past job history or performance evaluations; information from publicly available sources, such as social media platform, networking platform or employment profiles (e.g., LinkedIn, Lever or Greenhouse); your resume or CV, educational and employment background, professional certifications, and information and materials provided to us from third parties (e.g., employment agencies, recruitment firms, job boards and referral sources);
● “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
● “Sensory Data” such as audio, electronic, or visual information when you participate in telephone screens or video interviews with us;
● “Geolocation Data” such as physical location or movements;
● “Inferences” drawn from other personal information such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
● “Biometric Information” such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or drug test results.
SOURCE OF OBTAINING PERSONAL INFORMATION
Directly from you:
You enter or provide us with information in person, online, by email, by phone, by document upload, or during COVID-19 return to work procedures.
For example, when you apply for a job or update your information on file.
Directly and indirectly from you based on activity on our website or network:
For example, from internet browsing or network usage details collected automatically.
From vendors that interact with us in connection with your employment position:
For example, credit reporting agencies from which we check your credit in connection with a submitted employment application, vendors that provide background search results, vendors that assist in protecting you and us from fraud and identity theft; job board websites; benefits providers; employment agencies or recruiters.
USES OF PERSONAL INFORMATION
We respect your privacy, and we use and disclose personal information s permitted under applicable law, which includes, without limitation:
Hiring Process:
● Processing and reviewing your job application, and determining whether to extend an offer of employment and details related to a job offer;
● Verifying your identity and information, and to carry out reference checks and/or background checks;
● Communicating with you about the recruitment process, such as responses to your inquiries and requests, sharing information about benefits and other potential career opportunities at Snapdocs with you, and asking for feedback about your candidate experience with us;
● Analyzing and making improvements to our recruitment process;
● Fulfilling operational and business purposes, such as managing business activities, processes and practices;
● Protecting our business operations by detecting security incidents, such as malicious, deceptive, fraudulent or illegal activity, and taking appropriate action related to any security incidents;
● Complying with our legal, governmental and safety requirements and requests, including
any internal policies and procedures, and protecting our, your or others’ rights and property; and
● Managing potential public safety risks, including in relation to COVID-19, to individuals and applicants who come onsite, and the population generally.
Workforce Management:
● Recruiting, interviewing and evaluating job candidates and employees;
● Administration of payroll, wages and other compensation;
● Granting and administering equity awards, bonuses, commissions and other incentive awards;
● Administering and evaluating employee benefits, including healthcare, pensions, retirement and
savings plans and loans;
● Maintaining contact details of your designated dependents and beneficiaries and communicating with
them as necessary in the administration of your employee benefits and awards;
● Maintaining contact details of your designated emergency contacts and communicating with them as
necessary in emergencies;
● Administering and evaluating vacation, paid time off, sick leave, and other leaves of absence;
● Performance and compensation evaluation and promotions;
● Providing training and career development opportunities;
● Administering employee transfers, reassignments and secondments;
● Conducting employee surveys and soliciting employee feedback;
● Performing background, reference, or credit checks;
● Managing disciplinary matters, grievances and terminations;
● Administering business expense tracking, reimbursements and travel;
● Assisting with obtaining an immigration visa or work permit;
● Improving our application and/or recruitment process, including improving diversity;
● Accommodating disabilities or health conditions;
● Providing information technology resources and support;
● Maintaining internal employee directories;
● Communicating with you;
● Otherwise administering our employment relationship with you; and
● Analyzing our workforce and information relating to any of the activities above;
Business Operations:
Operating and managing our business, including managing communications and IT systems; research, development and operation of our products and/or services; managing and allocating Company assets and personnel; strategic planning and project management; business continuity; maintenance of business and audit records; budgeting, financial management and reporting; internal communications; promoting our business; physical and information security; and evaluating and undergoing mergers, acquisitions, sales, re-organizations or disposals and integration with purchasers.
Compliance, Safety and Fraud Prevention:
Complying with legal and other requirements, such as tax, audit, recordkeeping, reporting, verifying identity and eligibility to work, and equal opportunities monitoring requirements; complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities; protecting our, your or others’ rights, safety and property; investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and sharing information with government authorities, law enforcement, courts or private parties for the foregoing purposes.
Monitoring:
Monitoring offices and facilities, IT and communications systems, devices, equipment and applications through manual review and automated tools such as security software, website and spam filtering, and monitoring our physical premises (e.g., by using security cameras and keycard scans) to protect our, your or others’ rights, safety and property; operate, maintain and protect the security of our network systems and devices; protect our proprietary and confidential information and intellectual property; for recordkeeping and archiving; for personnel training and/or performance management; for the compliance, safety and fraud prevention purposes described above; to investigate and respond to security and other incidents; and for business continuity (such as monitoring business-related emails following an employee's departure).
Analytics:
Creating anonymous, aggregated or de-identified data that we use and share to analyze our workforce and business and for other lawful business purposes.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information with other parties as necessary for the purposes described in this Notice, including with:
● Service providers that provide us services related to the recruitment process, such as identity verification and other pre-employment screening providers, payment service providers, interview travel booking and expense reimbursement;
● Third parties including:
○ With affiliates, if any exist currently, we share Identifiers, Other Personal Information, Protected Characteristics, Internet or Network Activity, Professional or Employment Related Information, Commercial Information, Sensory Data, Geolocation Data, Inferences, Biometric Information;
○ With attorneys and background check companies we share Identifiers, Other Personal Information, Protected Characteristics, Internet or Network Activity, Sensory Data, Professional or Employment Related Information, Commercial Information, Sensory Data, Geolocation Data, Inferences, and Biometric Information;
○ With staffing agencies and job posting platforms we share Identifiers, Other Personal Information, Protected Characteristics, and Professional or Employment Related Information;
○ With insurance providers we share Identifiers, Other Personal Information, Protected Characteristics, and Professional or Employment Related Information;
○ With benefits providers we share Identifiers, Other Personal Information, Protected Characteristics, and Professional or Employment Related Information;
○ With advisors such as banks, credit card companies, accountants, financial advisors, and insurance providers, we share Identifiers, Other Personal Information, Protected Characteristics, and Professional or Employment Related Information;
○ With specialty services such as childcare and concierge services, and fitness and wellness providers, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, and Professional or Employment Related Information; and
○ With regulatory agencies we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation, Sensory Data, Professional or Employment Related Information, Biometric Information, and Inferences; and when such sharing involves health information, we maintain an employee’s anonymity whenever possible.
● Other companies in connection with a corporate transaction like a sale or merger of Snapdocs, including due diligence requests related to such corporate transaction; and
● Law enforcement, government entities, courts, and pursuant to legal process where required by law.
SALE OF PERSONAL INFORMATION
We do not sell your personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
ALTERNATE FORMATS OF THIS NOTICE
Upon request, this Notice is available in alternative formats, such as large print, braille, or audio. Please contact Rachel Fee by email at Rachel.Fee@snapdocs.com (with a copy to employee-experience@snapdocs.com) or by telephone at (732) 890-4105, and an alternative format will be provided to you so you can access the information in this Notice.
OTHER INFORMATION ABOUT THIS NOTICE
We reserve the right to change this Notice at any time and may apply any changes to previously collected personal information. When changes are made to this Notice, we will post a revised Notice with an updated “Effective Date” at the top of this Notice, and any changes, including any application to previously collected personal information, will be effective from such “Effective Date”.
This Notice does not address, and we are not responsible for, the privacy practices of third parties, which have their own rules for how they collect and use your personal information. Links to third party websites or services are not endorsements by Snapdocs.
Snapdocs’ Career site is not intended for minors under the age of 18.
If you have any questions or concerns regarding this Notice, our Privacy Policy or the collection of your personal information, please contact us at the following address or email: Snapdocs, Inc., 100 Montgomery St. #2400 San Francisco, CA 94104, Attn: Legal Dept, with an email copy to compliance@snapdocs.com.