California Privacy Policy

FOR CALIFORNIA RESIDENTS

PERSONAL INFORMATION THAT WE COLLECT ABOUT YOU

For individuals who are California residents, the California Consumer Privacy Act (CCPA) requires certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it.

Depending on how you interact with us, TalentWave may collect the following categories of information as summarized in the table below.

All categories of personal information we collect about you (as detailed below) come from the following categories of sources:

  • You
  • Automatically collected from you
  • Our affiliate companies
  • Third parties

WEBSITE

If you interact with us on our website we collect the following information:

Categories of Personal information We Collect Categories of Third Parties with Which We Share that Information
Identifiers(such as: name, address, email address, etc.)
  • Third Parties (such as our service providers and integration partners)
  • Our affiliate companies
  • Aggregators (such as analytic services)
Internet or Other network or Device Activity(such as browsing history or app usage)
  • Our affiliate companies
  • Aggregators (such as analytics services)

All the categories of personal information we collect about you (as detailed above) are used for the following purposes:

  • Providing our services (for example, account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about our services)
  • For our operational purposes, and the operational purposes of our service providers and integration partners
  • Improving our existing services and developing new services (e.g., by conducting research to develop new products or features)
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity
  • Bug detection, error reporting, and activities to maintain the quality or safety of our services
  • Auditing consumer interactions on our site
  • Other uses that we notify you about

FOR EMPLOYEES AND PAYROLLED WORKERS

If you are a temporary employee/payrolled worker of TalentWave performing services for one of TalentWave's clients, we collect the following information:

Identifiers And Professional Or Employment-Related Information
Personal Information Collected: TalentWave collects identifiers and professional or employment-related information, including the following:
  • Identifiers: real name, nickname or alias, postal address, telephone number, e-mail address, Social Security number, signature, online identifier, Internet Protocol address, bank account name and number for direct deposits, driver's license number or state identification card number, passport number, credit card number, and debit card number.
  • Professional or Employment-Related Information: compensation, bonuses, equity grants, pensions, benefits, attendance, evaluations, performance reviews, discipline, personnel files, expenses, education, corporate credit card details, membership in professional organizations, professional certifications, work eligibility in order to comply with legal requirements, and current and past employment history.

Purposes of Use:

Managing Personnel
  • To manage personnel and employment matters
  • To set up a personnel file
  • To administer compensation, bonuses, equity grants, other forms of compensation, and benefits
  • To manage vacation, sick leave, and other leaves of absence
  • To provide training
  • To evaluate job performance and consider employees for other internal positions
  • To develop a talent pool and plan for succession
  • Career development activities
  • For diversity and inclusion programs
  • To conduct employee surveys
  • To engage in crisis management
  • To fulfill recordkeeping and reporting responsibilities
  • To maintain an internal employee directory and for purposes of identification
  • To facilitate communication, interaction and collaboration among employees
  • To arrange team-building and other morale-related activities
  • To manage employee-related emergencies, including health emergencies
  • To promote TalentWave as a place to work
  • To arrange and manage Company-sponsored events and public service activities
  • Workforce reporting and data analytics/trend analysis
  • To design employee retention programs

Purposes of Use:

Monitoring, Security, And Compliance
  • To monitor use of TalentWave information systems and other electronic resources
  • To conduct internal audits
  • To conduct internal investigations
  • To protect the safety and security of TalentWave facilities
  • To report suspected criminal conduct to law enforcement and cooperate in investigations

Purposes of Use:

Conducting Our Business
  • For communications with prospective, current, and former customers
  • To make business travel arrangements
  • To engage in project management
  • To manage business expenses and reimbursements
  • To promote the business
  • To provide a directory and contact information for prospective and current customers business partners


Personal Information Categories From Cal. Civ. Code § 1798.80(e)

TalentWave collects categories of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in "Identifiers," above) as follows for the purposes listed below:
  • Photograph and physical description: (a) for security and internal identification purposes, and (b) to identify employees to co-workers, prospective and current customers, and other third parties;

  • Medical information: (a) to the extent necessary to comply with the TalentWave's legal obligations, such as to accommodate disabilities; (b) to conduct a direct threat analysis in accordance with the Americans with Disabilities Act; (c) for workers' compensation purposes; (d) for occupational health surveillance; (e) for occupational health and safety compliance and record-keeping; (f) to conduct fitness-for-duty examinations; (g) to administer leaves of absence and sick time; (h) to provide a wellness program; and (i) to respond to an employee's medical emergency.
Characteristics Of Protected Classifications Under California Or Federal Law

TalentWave collects information about race, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California's Fair Employment and Housing Act.

TalentWave also collects the following characteristics (in addition to those listed above) for its diversity and inclusion programs: (a) religion (includes dress and grooming practices and encompasses all aspects of religious belief, observance and practice); (b) sex (includes gender, pregnancy, childbirth, breastfeeding, or related medical conditions; also, sexual orientation); (c) disability; (d) gender identity; (e) gender expression; (f) marital status; (g) age, (h) familial status.

TalentWave also uses this Personal Information for purposes including: disability, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary to comply with the Family Medical Leave Act and California law; military and veteran status as necessary to comply with leave requirements under applicable law; age incidentally to the use of birth date for birthday celebrations and identity verification; religion and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary for accommodations under applicable law; national origin as necessary to comply with immigration laws; and marital status and familial status as necessary to provide benefits and for tax purposes.

TalentWave collects this category of Personal Information on a purely voluntary basis and uses the information only in compliance with applicable laws and regulations.

Commercial Information
  • Personal Information Collected: TalentWave collects commercial information including the following: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Purposes of Use: reimbursement of business expenses, auditing, data security, preventing illicit activity, providing services, research and development, error prevention, quality assurance and improvement, product and service training, order fulfillment, and marketing/advertising.
Education Information
  • Personal Information Collected: TalentWave collects education information, including the following: academic transcripts, educational discipline records, and academic counseling records.
  • Purposes of Use: to determine suitability for roles and promotions, to determine eligibility for a position.
Background Screening Information
  • Personal Information Collected: TalentWave collects background screening information, including results of the following types of background screening: criminal history; sex offender registration; motor vehicle records; credit history; employment history; drug testing; and educational history.
  • Purposes of Use: to screen employees for risks to TalentWave and continued suitability for a position.
Purposes Potentially Applicable To any of the Categories of Personal Information Listed Above

TalentWave also may use employees' Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:

  • to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
  • to manage litigation involving TalentWave, and other legal disputes and inquiries and to meet legal and regulatory requirements
  • in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company or any of its subsidiaries or affiliates; and
  • to manage licenses, permits and authorizations applicable to the TalentWave's business operations.

FOR INDEPENDENT CONTRACTORS

If you are an independent contractor performing services for one of TalentWave's clients, we collect the following information:


Identifiers And Professional or Work-Related Information
  • Personal Information Collected: TalentWave collects identifiers and professional or work-related information, including the following:
  • Identifiers: real name, nickname or alias, postal address, telephone number, e-mail address, Social Security number, signature, online identifier, Internet Protocol address, bank account name and number for direct deposits, driver's license number or state identification card number, passport number, credit card number, and debit card number.
  • Professional or Work-Related Information: contractual agreement, invoices reflecting time worked, contract deliverables, contract payments, tax-related information, insurance information, licensing and certifications.

Purposes of Use:

Managing Personnel
  • To evaluate Contractors' qualifications for engagements
  • To negotiate and execute the agreement with the Contractor
  • To administer the relationship with the Contractor
  • To make contract payments
  • To evaluate Contractors' deliverables or performance of the contract
  • For recordkeeping purposes
  • To maintain an internal directory and for purposes of identification
  • To determine a Contractor's licensure for an engagement
  • To determine a Contractor's certifications for an engagement

Purposes of Use:

Monitoring, Security, And Compliance:
  • To monitor use of TalentWave information systems
  • To conduct internal audits
  • To conduct internal investigations
  • To safeguard the TalentWave's proprietary information
  • To protect the safety and security of the Company's facilities
  • To report suspected criminal conduct to law enforcement and cooperate in investigations

Purposes of Use:

Conducting Our Business:
  • For communications with prospective, current, and former customers and/or the Contractor
  • To provide a directory and contact information for prospective and current customers and business partners


Personal Information Categories From Cal. Civ. Code § 1798.80(e)

TalentWave collects types of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in "Identifiers," above) as follows for the purposes listed below:

  • Medical information: to respond to a medical emergency
Commercial Information
  • Personal Information Collected: TalentWave collects commercial information including the following: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Purposes of Use: to comply with contractual reimbursement obligations.
Education Information
  • Personal Information Collected: TalentWave collects education information, including the following: academic transcripts, educational discipline records, and academic counseling records.
  • Purposes of Use: to determine suitability for engagement as a Contractor.
Background Screening Information
  • Personal Information Collected: TalentWave collects background screening information, including results of the following types of background screening: criminal history; sex offender registration; motor vehicle records; credit history; employment history; drug testing; and educational history.
  • Purposes of Use: to screen Contractors for risks to TalentWave and suitability to provide the contracted services.
Purposes Potentially Applicable To any of the Categories of Personal Information Listed Above

TalentWave also may use employees' Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:

  • to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
  • to manage litigation involving TalentWave, and other legal disputes and inquiries and to meet legal and regulatory requirements
  • in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company or any of its subsidiaries or affiliates; and
  • to manage licenses, permits and authorizations applicable to the TalentWave's business operations.

CALIFORNIA RIGHTS AND CHOICES

Subject to certain restrictions, California residents have the right to request that we disclose what personal information we collect about you, to delete any personal information that we collected from or maintain about you, and to opt-out of the sale of personal information about you. As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, including our means of verifying your identity. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us Compliance2@TalentWave.com.

Accessing and Deleting Your Personal Information
  • Right to request access to your personal information
    • California residents have the right to request that we disclose what categories of personal information that we collect, use, or sell about you. You may also request the specific pieces of personal information that we have collected about you.
  • Right to deletion of your personal information
    • You may also request that we delete any personal information that we have collected from/about you. However, we may retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, as necessary for us, or others, to exercise their free speech or other rights, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.
  • How to exercise your access and deletion rights
    • California residents may exercise their California privacy rights by submitting your request Compliance2@TalentWave.com.

For security purposes, we may request additional information from you to verify your identity when you request to exercise your California privacy rights.

Sales of Personal Information

California residents may opt out of the "sale" of their personal information. TalentWave does not "sell" your personal information as we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations.

Non-Discrimination Rights

California residents have the right to not be discriminated against for exercising their rights as described in this section. We will not discriminate against you for exercising your CCPA rights.