Privacy Policy for California Workforce Members

This Privacy Policy for California Workforce Members, as provided by Group USA Inc. ("Company," "we," or "us"), supplements the information contained in our Privacy Policy https://camillelavie.com/pages/privacy-policy and applies solely to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals who reside in the State of California (“Workforce Members”, “consumers,” or "you").

We adopt this privacy policy to comply with the California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of 2020 (CPRA), implementing regulations, and any terms defined in the CCPA or CPRA have the same meaning when used in this Policy.

Changes to Our Privacy Policy

 We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated privacy policy in our intranet (where it may be found in the “Store Folders”) and update the effective date. Your continued employment following the posting of changes constitutes your acceptance of such changes.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, and/or could reasonably be linked, directly or indirectly, with a particular Workforce Member and his/her/its/their household or device ("personal information"). Personal information does not include:

• publicly available information from government records;
• deidentified or aggregated Workforce Member information;
• information excluded from the CCPA's scope, such as:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA),
• clinical trial data, or
• other qualifying research data; and 
• personal information covered by certain sector-specific privacy laws, including
• the Fair Credit Reporting Act (FCRA),
• the Gramm-Leach-Bliley Act (GLBA),
• the California Financial Information Privacy Act (FIPA), and
• the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from Workforce Members within the last twelve (12) months:

Personal Information 

The following categories of information may be collected, collected on behalf of or shared with our service providers, and retained for the duration of employment and three (3) years following termination of employment with the Company; provided, however, that we do not sell or share the following categories of personal information for non-business purposes:

Personal Information Category	Business Purpose
Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver's license or state identification numbers, and similar information for your dependents and beneficiaries.	Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks Conduct employee onboarding Seek and process independent contractor arrangements Maintain and administer independent contractor payments Maintain and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and complying with record retention requirements Provide independent contractors with any data maintenance and support services Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Communicate with independent contractors and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Ensure employee productivity and adherence to Company policies Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy Respond to law enforcement requests and as required by applicable law or court order Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information.	Same purposes as for identifiers category
Protected classification characteristics under California or federal law, 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, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information).	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits, grievances, and suspected violations of Company policy  Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
Commercial information, such as transaction information, purchase history, and financial details.	Respond to law enforcement requests and as required by applicable law or court order
Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns, and certain wellness metrics.	Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits Administer and design health wellness programs Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
Internet or other similar network activity information, including all activity on the Company's information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee's use of company-issued devices).	Facilitate the efficient and secure use of Company information systems Ensure compliance with Company information systems policies and procedures. Comply with applicable state and federal laws Prevent unauthorized access to, use, or disclosure or removal of the Company's property, records, data, and information Enhance employee productivity Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
Geolocation data, such as the time and physical location related to use of an internet website, application, or device, and GPS location data from mobile devices of employees who participate in our vehicle reimbursement program.	Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company's policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company's policy
Surveillance data, such as monitoring and video surveillance.	Comply with applicable state and federal laws, including on workplace health and safety Prevent unauthorized access, use, or loss of the Company property Improve customer service Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members.	Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding Design and administer employee benefit plans and programs, including for leaves of absence. Maintain personnel records and comply with record retention requirements. Communicate with employees and their emergency contacts and plan beneficiaries. Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws. Prevent unauthorized access to or use of the Company's property, including its information systems, electronic devices, network, and data. Ensure employee productivity and adherence to the Company policies. Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy. Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts.	Evaluate an individual's appropriateness for hire, or promotion or transfer to a new position at the Company.

 

Sensitive Personal Information

Sensitive personal information is a subtype of personal information consisting of specific information categories. The following categories of sensitive personal information may be collected, collected on behalf of or shared with our service providers, and retained for the duration of employment and three (3) years following termination of employment with the Company; provided, however, that we do not sell or share the following categories of personal information for non-business purposes:

Sensitive Personal Information Category	Business Purpose
Government identifiers, such as your Social Security number, driver's license, state identification card, and passport and visa information, and immigration status and documentation.	Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks Process and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and comply with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Respond to law enforcement requests and as required by applicable law or court order
Complete account access credentials, such as usernames, account numbers, or card numbers combined with required access/security code or password.	Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks. Provide employees with human resources management services and employee data maintenance and support services Prevent unauthorized access to or use of the Company information systems, electronic devices, network, and data
Racial or ethnic origin.	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy
Union membership.	Implement appropriate policies and procedures Deduct union dues from paychecks
Genetic data.	Investigate and process workers' compensation claims Process health insurance claims Conduct and process employment testing
Unique identifying biometric information.	Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits. Ensure accurate time records Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents
Health information, including job restrictions and workplace illness and injury information.	Investigate and process workers' compensation claims Process health insurance claims Conduct and process employment testing Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries

 

Sources

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. By way of example but not limitation, this includes your completion of Company forms required for employment.
• Indirectly from you. By way of example but not limitation, this includes observing your actions on information systems owned or maintained by us.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes: 

• fulfilling or meeting the reason you provided the information. For example, if you share your name and contact information as part of an employment application, we will use that personal information to review and assess your application, including without limitation to verify right to work, verifying references and background checks;
• conducting our business;
• maintaining the safety, security, and integrity of our business, products and services, databases and other technology assets, and business;
• testing, researching, analyzing, and product development, including to develop and improve our business, products, and services;
• for processing compensation, administering benefits and other employment related taxation and other similar state or federal mandated employee/employer reporting or collection;
• for determining eligibility for employee benefits and/or different positions within the Company;
• to protect Company facilities, property, devices and systems;
• responding to law enforcement requests and as required by applicable law, court order, or governmental regulations; or
• as described to you when collecting your personal information or as otherwise set forth in the CCPA.
• Additionally, if we are considering a corporate restructure or other such event, we may share or sale your data when evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Workforce Members is among discussions for assets to be transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We do not sell personal information. We may share your personal information, including sensitive personal information, by disclosing it to a third party, including our service providers, for a business purpose.

We may make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
A: Identifiers.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
B: California Customer Records personal information categories.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
C: Protected classification characteristics under California or federal law.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
D: Commercial information.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
E: Biometric information.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
F: Internet or other similar network activity.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
G: Geolocation data.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
H: Sensory data.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
I: Professional or employment-related information.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits
J: Non-public education information.	Organizations that conduct credit, background, and driving records checks Organizations, such as ADP, that administer employee benefits

 

 Your Rights and Choices 

The CCPA, as amended by the CPRA, provides Workforce Members with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

• the categories of personal information we collected about you;
• the categories of sources for the personal information we collected about you;
• our business or commercial purpose for collecting or selling that personal information;
• the categories of third parties with whom we share that personal information;
• if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased, and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and 
• the specific pieces of personal information we collected about you (also called a data portability request).
• Upon a verifiable request, we will transfer that information to another entity directly.
• However, before responding to a verifiable request, we are required by law and regulations to remove certain sensitive information from collected personal information, including:
• social Security numbers (SSNs), driver's license numbers, or other government-issued identification numbers;
• financial account numbers;
• health insurance or medical identification numbers;
• account passwords or security questions and answers; and
• unique biometric data generated from measurements or technical analysis of human characteristics.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies.

NOTE that your right to delete is not an absolute right and we may deny deletion requests when we need to retain personal information for certain statutory business reasons. 

In particular, we may deny your deletion request (even in part) if retaining any of the information is necessary for us or our service provider(s) to perform the following:

• employment purposes, such as for payroll, government data reporting, and health care;
• performing a contract between the business and Workforce Members, such as to award employee benefits;
• retaining personal information contained in security logs to satisfy compliance requirements and litigation demands;
• complying with a legal obligation or other laws applicable to the Company, such as needing to retain certain employment records for the required data retention period;
• detecting security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• debugging products to identify and repair errors that impair existing intended functionality;
• solely internal uses that are reasonably aligned with Workforce Member expectations based on your relationship with us;
• to defend or pursue proceedings, claims or actions by you against us or our claims against you in relation to your employment or sought employment with us; and
• making other internal and lawful uses of that information that are compatible with the context in which you provided it.

Upon a verifiable request, we will inform and explain whether or not we have complied with the request and, if so, delete or deidentify personal information not subject to one of these exceptions from our records.

Otherwise, we will notify our service providers or contractors to delete your personal information from their records and all third parties to whom it has sold or shared your personal information to delete that information, unless the notification proves impossible or involves disproportionate effort.

However, we may not delete personal information created or received from others, such as background or reference check results, performance evaluations, tax-related records, benefits records, investigation reports, and related emails required by applicable laws, rules and regulations.

 Right to Correct

You have the right to request that we correct inaccurate personal information, accounting for the nature of the personal information and the purposes of the processing of the personal information, subject to certain limitations.

NOTE that your right to delete is not an absolute right and we must take the personal information's processing purposes and general nature into account.

However, we will use commercially reasonable efforts to correct the inaccurate personal information upon a verifiable request.

Right to Restrict Sensitive Personal Information Processing

You have the right to restrict how we use and disclose sensitive personal information that we collect or process with the purpose of inferring characteristics about you, subject to certain limitations. 

Exercising Your Rights 

To exercise your rights described above, please submit a request by either: 

• Calling us at 862-895-5089
  
• Emailing us at payrollgroup@clv.com
• Visiting camillelavie.com
• Log into your ADP Total Source account at https://login.adp.com/welcome.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include legal documents; and
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. 

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-business day timeframe, please contact ADP Employee Assistance Hotline 1-866-574-7256.

We endeavor to substantively respond to a verifiable Workforce Member request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Workforce Member request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

You have the right to direct us to not sell your personal information at any time (the "right to opt-out"), though we may continue to share your information with service providers. Workforce Members who opt-in to personal information sales may opt-out of future sales at any time. 

To exercise the right to opt-out, you (or your authorized representative) may contact us or submit a request form by visiting https://camillelavie.com/pages/contact.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

However, if you wish to opt back in to personal information sales, may contact us or submit a request form by visiting https://camillelavie.com/pages/contact.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your CCPA/CPRA rights. 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

To make such a request, please send an email to payrollgroup@clv.com or write us at: 61 W. Palisade Ave., Englewood, NJ 07631.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

If you need to access this Notice in an alternative format due to having a disability, please contact payrollgroup@clv.com and 862-895-5089.