Privacy Policy

STROTTMAN

CALIFORNIA PRIVACY POLICY

 

The following Privacy Policy explains the type of personal information and sensitive personal information that the Company (“we”, “us” or “our”) may collect about You and how we may use it. Under this policy, “you” means prospective, current, former employees, temporary employees, agents, subcontractors, and vendors.

 

1. Definitions:

 

1. Personal Information: Under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), personal information includes:

   1. Real name;

   2.  Address;

   3. Social Security Number;

   4. IP Address;

   5. Geolocation;

   6. Internet Activity;

   7. Personal characteristics, behavior, religious or political affiliations, sexual preferences, employment and educational data, financial and medical information. 

 

1. Sensitive Personal Information: This is a subset of personal information that relates to information that may be deemed more sensitive in nature. Sensitive Personal Information includes:

   1. Identifying information that is not publicly available (Social Security number, driver’s license number, state ID card, or passport number);

   2. Log-in information, financial account information;

   3. Precise geolocation;

   4. Racial, ethnic origin, religious or philosophical beliefs, or union membership;

   5. Emails, mail, text messages – unless the Company is the intended recipient;

   6. Any genetic information; 

   7. Biometric information (facial recognition and fingerprint);

   8. Health information;

   9. Sexual preference or information concerning sex life.

 

1. Categories of Personal Information and Sensitive Personal Information Collected.  In the past twelve (12) months, we have collected the following information: 

• Identifiers, such as name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);

• Personal information, such as real name, signature, SSN, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, passport number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, employment history, bank account number, other financial information, medical information, or health insurance information;

• Characteristics of all protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, and medical conditions;

• Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements [or purchases from Company]);

• Internet or network activity information, such as browsing history and interactions with our online systems and websites and any personal information that you provide while accessing the Company’s computer systems, such as personal credit card information and passwords;

• Geolocation data, such as device location from usage of the Company’s devices;

• Biometric information related to access to the Company’s secured access points;

• Audio, electronic, visual, and similar information;

• Professional or employment-related information, such as work history and prior employer;

• Non-public education information; and

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

 

Depending on a particular California resident’s interaction with us, we may not have collected each of these categories of Personal Information and Sensitive Personal Information about that person.

 

1. Sources of Personal Information and Sensitive Personal Information.  The Company collects information about you from the following sources: 1) you; 2) prior employers, references, recruiters, job-related social media platforms; 3) third-party sources of demographic information; 4) third-party companies, such as background check companies, drug testing facilities; and 5) claim administrators and investigators. Depending on the Company’s interactions with you, we may or may not collect all of the information identified about you.  

 

1. Uses of Personal Information and Sensitive Personal Information.  We may use Personal Information and Sensitive Personal Information:

• To operate, manage, and maintain our business;

• For hiring, retention, and employment purposes;

• To otherwise accomplish our business purposes and objectives, including, for example:

  • Emergency services;

  • Conducting research, analytics, and data analysis;

  • Maintaining our facilities and infrastructure;

  • Quality and safety assurance measures;

  • Conducting risk and security controls and monitoring;

  • Protecting confidential and trade secret information;

  • Detecting and preventing fraud;

  • Performing identity verification;

  • Performing accounting, audit, and other internal functions, such as internal investigations;

  • Complying with the law, legal process, and internal policies;

    • Maintaining records;

    • Claims processing;

    • Responding to legal requests for information and subpoenas; and

    • Exercising and defending legal claims.

• Any other purposes authorized by the California Privacy Protection Agency, California or Federal law.

 

We may or may not have used Personal Information and Sensitive Personal Information about you for each of the above purposes.

 

1. Selling or Sharing of Personal Information and Sensitive Personal Information: The Company DOES NOT sell your Personal Information and Sensitive Personal Information. However, the Company shares your Personal Information and Sensitive Personal Information with the following third-parties:

 

1. Payroll Service - Paylocity;

2. Benefits provider – Ease.com (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

3. Benefits provider – Anthem (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

4. Benefits provider -  Kaiser (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

5. Benefits provider – Mutual of Omaha (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

6. Benefits provider – VSP (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

7. Benefits provider -  Fidelity (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

8. Benefits provider -  Travelers (health insurance, workers’ comp insurance, eye/dental insurance, 401k and/or retirement plan)];

9. Performance Review Provider – Engagedly (online performance management;

10. Retirement Broker/Planner – StoneKimbro

11. Health Insurance Broker – Brent Hanson

12. Retirement Plan Account Maintenance – PBU Inc (annual testing/compliance)

13. IT helpdesk computer set-up - Nuebis

14. Company’s Legal Counsel and investigators;

15. Your Bank or recipient of Direct Deposit.

 

The type of information that we share with third-parties listed above, includes but is not limited to, the following:

 

1. Identifiers, such as name, government-issued identifier (e.g., Social Security   number), and unique identifiers (e.g., employee ID);

2. Personal information, as defined in the California Records Law, such as name, signature, SSN, 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, or any other financial information, medical information, or health insurance information;

3. Characteristics of protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, and medical conditions;

4. Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements);

5. Internet or network activity information, such as browsing history and interactions with our online systems and websites;

6. Geolocation data, such as device location;

7. Audio, electronic, visual, and similar information, such as call and video recordings;

8. Professional or employment-related information, such as work history and prior employer;

9. Non-public education information; and

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

 

1. Data Retention Period.

The Company retains the information it receives about you for a period of: 7 years, unless a shorter or longer period is required by California or Federal law.

 

1. Your Rights.

Pursuant to the statute, employees have several rights under the CCPA and CPRA:

• Knowledge of information collected;

• Deletion of information collected;

• Opt-out of information collected;

• Opt-in of information collected;

• Correction of information collected;

• Go to court;

• Limit use of information collected;

• Not to be discriminated or retaliated against for exercising rights under the law.

 

1. Anti-Discrimination and Anti-Retaliation. The Company does not discriminate nor retaliate against persons who seek to enforce their rights under the CCPA and CPRA. If an individual believes they are being discriminated against or retaliated against for enforcing their rights under this policy, please contact Ben Carlson immediately to report this.  

 

1. For Inquiries and/or to Submit Requests for Information, Deletion or Correction.

Please contact either: (1) Ben Carlson, 949-623-7915, bcarlson@strottman.com, 258 Executive Park, Suite 200, Irvine, CA 92614, or (2) 949-623-7900 for inquiries about the Company’s policy, or to submit your requests for information, deletion or correction.

 

1. No Expectation of Privacy While Using The Company’s Technology.

While limited use of the Company’s equipment and technology for personal use is inevitable, you should have no expectation that anything you disclose while utilizing the Company’s equipment and technology will remain confidential to you.

 

E-mail.  E-mail communications are not private, and there should be no expectation of privacy regarding the content of any e-mail sent through the Company, either internal or external.  E‑mail messages are accessible, and may be accessed, by persons other than the sender or recipient, and the Company reserves the right to designate authorized personnel to monitor messages, and to disclose such messages and files on an “as needed” basis.  This may include the review, copying or deletion of messages or files by authorized persons.  The existence of passwords and message delete functions does not restrict or eliminate the Company’s ability or right to access e‑mail.

 

Computers and Other Devices.  The Company provides computers, cell phones, tablets, data storage devices, computer files, voicemail, the e-mail system, and other business equipment to assist employees in performing their job duties more quickly and efficiently.  The Company’s computer system, including all data files and applications, is the property of the Company.  All materials and information created, transmitted or stored on or through this system are the property of the Company and may be accessed by authorized personnel.  Users should not have any expectation of privacy with respect to such materials and information.  Any unauthorized access or use of the Company’s computer system is strictly prohibited.  To ensure that its communication systems and equipment are being used properly and in compliance with Firm policies, the Company, without notice, may periodically access, display, copy or listen to any messages, information, files, or communications sent, received, created, or stored through or in its systems and equipment, in accordance with applicable law. 

 

Internet.  The Company has the right to monitor usage of the Internet by employees who are accessing the Internet through the Company’s Computers and Other Devices, including, but not limited to, monitoring sites employees visit on the Internet (including social media sites), reviewing, printing and copying material downloaded or uploaded by employees, including Personal Information or Sensitive Personal Information, and reviewing, printing and copying e-mail sent and received by employees.  Internet use is not private and no individual should have any expectation of privacy in terms of their usage of the Internet or as to anything they create, store, send, or receive on or through the Company’s Computers and other Devices to the Internet.