California EMPLOYEES, APPLICANTS, AND CONTRACTORS Resident Privacy Notice

(VER 2023-2024)

This California Resident Privacy Notice supplements the privacy policy of  Minim, Inc. and its wholly owned subsidiaries MTRL LLC and Cadence Connectivity, Inc. (collectively "Minim”)  and applies to EMPLOYEES, APPLICANTS, AND CONTRACTORS who are California residents from whom the company collects Personal Information and Sensitive Personal Information (both as defined below) on our own behalf or on behalf of companies that have contracted with Minim to deliver services to others, including California residents in their capacity of Employees, Applicants, and Contractors.

1. Definitions

  1. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA or the CPRA, except such information that is (i) lawfully made available from government records, (ii) de-identified or aggregated, (iii) information made publicly available by the consumer or information from widely distributed media, (iv) lawfully obtained, truthful information that is a matter of public concern  or (v) otherwise excluded from the scope of the CCPA or CPRA. 
  2. "Sensitive Personal Information" means information that reveals:
    1. social security, driver’s license, state ID, or passport numbers;
    2. account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
    3. precise geolocation;
    4. racial or ethnic origin, religious or philosophical beliefs, or union membership;
    5. contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication;
    6. genetic data;
    7. biometric data processed for the purpose of uniquely identifying a consumer;
    8. personal information concerning a consumer’s health; or
    9. personal information concerning a consumer’s sex life or sexual orientation.
  1. “CCPA” means the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as such may be amended or superseded from time to time.
  2. “CPRA” means the California Privacy Rights Act of 2020 and its implementing regulations, as such may be amended or superseded from time to time.  The CPRA amends existing provisions of Title 1.81.5 of the California Civil Code (currently known as the CCPA) and adds new provisions.

2. Method of Collection of Personal Information and/or Sensitive Personal Information

  1. Like the CCPA, the CPRA requires that businesses provide consumers with certain information at or before the point of collecting personal information (Notice at Collection).  The CPRA increases the amount of information that must be provided in that notice.  In addition to the categories of personal information to be collected and the purposes for which the personal information is used, the CPRA will require that the Notice at Collection also include:
    1. Whether the collected Personal Information is Sold or Shared.
    2. If the business collects Sensitive Personal Information (including the ‘categories’ and ‘purposes’ for which such info will be used).
    3. The length of time the business intends to retain each category of personal information, including sensitive personal information (if it is not possible to provide specific lengths of time, the business must disclose the criteria it uses to determine such period).
    4. If you are eligible for enrollment in health/medical plans, retirement plans, and other fringe benefits offered by Minim, you need to refer to those respective Third Party Service Providers’ privacy policies  regarding their utilization of your data (including Personal Information and/or Sensitive Personal Information), and how long they retain such data.
  1. In the preceding twelve (12) months, Minim HAS collected Personal Information from you in the process of onboarding you as an Employee, Applicant, or Contractor, and/or in continuing to employ you as an Employee, Applicant, or Contractor.
  2. In the preceding twelve (12) months, Minim HAS collected Sensitive Personal Information from you in the process of onboarding you as an Employee, Applicant, or Contractor, and/or in continuing to employ you as an Employee, Applicant, or Contractor. 

3. Collection, Sale, and Sharing of Personal Information and/or Sensitive Personal Information

  1. In the preceding twelve (12) months, Minim has only Collected Personal Information as set forth in Table 1.  To be clear, Minim has not Sold or Shared any of your Personal Information for monetary or other valuable consideration.

Table 1

 

Information Types

1

Identifiers, such as name and government-issued identifier (e.g., Social Security number);

2

Personal information, as defined in the California safeguards law, including without limitation, 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, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

3

Characteristics of protected classifications under California or federal law, including without limitation, age, gender, medical conditions, marital status, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), race, color, religion or creed, ancestry, national origin, disability, genetic information, AIDS/HIV status, sexual orientation, gender identity and expression, citizenship, primary language, immigration status, military/veteran status, political affiliation/activities, domestic violence victim status, and request for leave;

4

Commercial information, such as transaction information and purchase history;

5

Biometric information, such as face scans, fingerprints and voiceprints;

6

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

7

Geolocation data, such as device location;

8

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

9

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

 

10

Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and

 

11

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

 

 

4. Sources of Personal Information and/or Sensitive Personal Information

  1. Minim collects this Personal Information voluntarily directly from the California residents themselves during the application process or when they otherwise contact Minim
  2. Minim may combine personal information you voluntarily provide to us with information we collect from other sources, such as:
    1. Recruiters;
    2. Prior employers and professional references;
    3. Educational institutions;
    4. Pre-employment screening and background check services;
    5. Credentialing and licensing organizations;
    6. Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
    7. Other sources as directed by you

5. Business Purpose of Use of Personal Information and/or Sensitive Personal Information

  1. Pursuant to our Privacy Policy, we Share your Personal Information and/or Sensitive Personal Information noted in Table 1 above with our service providers and affiliates, for the reasons listed below:  

Table 2

 

Information Types

1

To Recruit Employees, including to conduct employment related background screening and checks.

2

To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

3

To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

4

To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff restructuring.

5

To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee’s work related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

6

To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

7

To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements and populating the International Mobility global system.

8

To Maintain Your Contact Information, including altering your details across relevant entities within the Lever group of companies (for example personal, other employment and transferring roles).

9

To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

10

To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

11

To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.

12

To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

13

To Ensure a Safe and Efficient Working Environment, which includes Lever actions relating to disciplinary actions, and code of conduct processes and investigations.

14

To Maintain Security on Minim Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Lever’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

15

To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

 

    1. Local, State or Federal Authorities
      1. See Section 10(g)(ii) and (vi) of the Privacy Policy
    2. Minim’s professional service providers 
      1. See Section 10(g)(i) of the Privacy Policy.

6. Sharing of Personal Information and Sensitive Personal Information

  1. We may share your personal information for the business purposes described in this California Employee Privacy Notice with the following parties:
    1. Affiliates and Subsidiaries: We may share your personal information with our affiliates and subsidiaries.
    2. Service Providers: We may share your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers and others.
    3. Governmental Authorities: As required by law or legal process, we may share your personal information with federal or state regulatory agencies, law enforcement, courts and other governmental authorities.
    4. Professional Advisors: We may share your personal information with our professional advisors, such as auditors and law firms.
    5. Parties Involved with Business Transfers: We may share your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
  2. In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or CPRA. 

7. California Privacy Rights

  1. California residents may exercise the following rights:
    1. Right to Know and Access / “Shine the Light”
      1. See Section 11(a)(v) and (vi) of our Privacy Policy. 
      2. Effective 1/1/23, the calendar year limitation will be removed for California EMPLOYEES, APPLICANTS, AND CONTRACTORS who are California residents.  Such California residents will be able to request access to all of the Personal Information and/or Sensitive Personal Information that Minim possesses that was collected from them on or after January 1, 2022.  Personal Information and/or Sensitive Personal Information will be provided for periods prior to January 1, 2022, to the extent that doing so is neither impossible nor involve a disproportionate effort.  Unless otherwise mandated by law, Minim is not  required to keep personal information or sensitive personal information for any specific period of time.
    2. Right to Delete
      1. See Section 11(d) of our Privacy Policy.
      2. Under the CPRA, this obligation to delete is extended to businesses (Service Providers/Contractors and Third Parties) Minim has Shared Personal Information and/or Sensitive Personal Information with to delete info when a deletion request is received, to the extent that such a request is not Impossible or Involves disproportionate effort.  
      3. Note, however, that Minim may deny the request If the Personal Information and/or Sensitive Personal Information is reasonably necessary for certain processing activities.
    3. Right to Equal Service and Price
      1. Use and disclosure of Personal Information and/or Sensitive Personal Information
        1. Use and disclosure of your Personal Information and/or Sensitive Personal Information is necessary and inherent to Minim’s ability to engage with you as an EMPLOYEE, APPLICANT, or CONTRACTOR. 
        2. If you revoke Minim’s ability to use and disclose your Personal Information, Minim will be unable to continue to engage with you as an EMPLOYEE, APPLICANT, or CONTRACTOR  
    4. Right to Submit Requests 
      1. To exercise your rights under the CCPA / CPRA, please email us at CAHRdata@minim.com.
    5. Right to Rectification (Correction)
      1. See Section 11(c) of our Privacy Policy
      2. Under the CPRA, this obligation to Correct/Update is extended to businesses (Service Providers/Contractors and Third Parties) Minim has Shared Personal Information and/or Sensitive Personal Information with to Correct/Update info when a request is received, to the extent that such a request is not Impossible or Involves disproportionate effort.  
    6. Right to be Informed of Data Retention 
    7. EMPLOYEES, APPLICANTS, AND CONTRACTORS Timelines:
      1. Minim will confirm the receipt of any requests within 10 business days.
      2. Minim will respond to opt-out and/or other information requests within 45 calendar days.
      3. The default time frame that Minim will maintain request records logs is 7 years, but is subject to the further terms detailed in the “Minim Data Retention and Disposal Policy”.
      4. If you are eligible for enrollment in health/medical plans, retirement plans, and other fringe benefits offered by Minim, you need to refer to those respective Third Party Service Providers’ privacy policies  regarding their utilization of your data (including Personal Information and/or Sensitive Personal Information), and how long they retain such data.

8. Service Providers/Contractors and Third Party Authorization

  1. Where you access Minim’s services as a result of Minim’s contractual obligations to a third party (e.g., your employer), we require that you contact us via an email address currently associated with your account and that the third party that you have contracted with to receive the service verify that the requested actions should be taken. 

9. Accessing Alternative Formats of this Notice

  1. If you have a disability or would like to access this notice in an alternative format, please contact us at CAHRdata@minim.com.

10. How to Contact Us About this Notice

  1. You may reach us by email at CAHRdata@minim.com if you have any questions about this Policy.
  2. You may also reach us by phone at our toll free number 1.833.96.MINIM to discuss this policy or make a rights based request for action relating to your Personal Information and/or Sensitive Personal Information.

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