Effective Date: September 21, 2023
This Privacy Notice Addendum for California Residents (the “CA Privacy Notice”) supplements the information contained in the Newfold Digital, Inc. Privacy Notice (the “Privacy Notice”), and applies solely to residents of California, including job applicants, (“consumers” or “you”). Job applicants who receive an offer of employment may receive additional requests for information along with additional privacy notices. This CA Privacy Notice does not apply when we are acting as a service provider and processing personal information on behalf of our customers.
In addition to the rights described, where the California Consumer Privacy Act 2018 (“CCPA”) or related data protection laws apply, you may:
Request to know the categories of personal information we collect about you, as well as the sources from which the personal information is collected; the business or commercial purpose of our collection; the categories of third parties with whom we provide your personal information; and the specific pieces of personal information we hold about you.
Request certain information regarding the opt out of our disclosure of your personal information to third parties.
Request that we delete the personal information we hold about you in certain limited circumstances.
We collect personal information, meaning information that identifies, relates to, references, describes, or is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or device. For the purposes of this CA Privacy Notice, personal information does not include:
Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.
We collect personal information from and about consumers for a variety of business purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the “Categories of Information We Collect From You” and “How We Use Your Information” sections in our Privacy Notice.
In the last 12 months, we have collected the following categories of personal information from the sources and for the purposes stated below.
We collect this information from you when you attend conferences, visit our websites, establish an account or use our online job application portal. We use this information to stay in contact with you for business purposes, confirm your identity and authenticate you, during the job application process and to satisfy regulatory requirements.
Personal Identifiers: Name, alias, date of birth, driver’s license or state identification card number or passport number.
Contact Information: home, postal or mailing address, home phone number, cell phone number email address, or other similar identifiers.
Commercial Information: Services purchased and information relating to your use of our Services.
Internet/Network Information: IP address, browser or device information.
Other Personal Information: Information you provide to us when you register for or attend an event organized or hosted by us, information you permit us to see when interacting with us through social media, or comments and opinions you provide to us such as when you post on message boards, blogs or complete an online form.
Inferences: Information generated from your use of the websites reflecting predictions about your interests and preferences.
Sensitive Personal Information: Certain information such as social security, driver's license, state identification card, or passport number may be collected to confirm your identify or facilitate payment. However, we do not use or disclose the information for any reason except as necessary to perform the Service requested, process your job application or meet our legal obligations.
Pre-Hire Information: Information provided in your job application or resume, information gathered as part of background screening and reference checks, information recorded in job interview notes by persons conducting job interviews for the company, information contained in candidate evaluation records and assessments, information in work product samples you provided, voluntary disclosures by you, and Wage Opportunity Tax Credit (WOTC) information.
Protected Classifications: Race, ethnicity, national origin, sex, gender, sexual orientation, gender identity, religious or philosophical beliefs, age, physical or mental disability, medical condition, veteran or military status, familial status, language, or union membership when volunteered or required by law.
Employment History: Information regarding prior job experience, positions held, and when permitted by applicable law your salary history or expectations.
Inferences: Based on analysis of the personal information collected, we may develop inferences regarding a job applicants’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes for purposes of employment.
Education Information: Information contained in your resume regarding educational history and information in transcripts or records of degrees and vocational certifications obtained.
The Personal Information and Sensitive Personal Information we collect from job applicants, and our use of Personal Information and Sensitive Personal Information, may vary depending on the circumstances. Generally, we may use or disclose Personal Information and Sensitive Personal Information we collect from you or about you for one or more of the following purposes:
To fulfill or meet the purpose for which you provided the information. For example, if you provide your name and contact information to become an employee, we will use that Personal Information in connection with that process.
To comply with local, state, and federal law and regulations requiring employers to maintain certain records (such as immigration compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records), as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19.
To manage and process payroll and/or company travel and expenses.
To evaluate job applicants and candidates for employment or promotions.
To obtain and verify background checks on job applicants and employees and to verify employment references.
To evaluate, make, and communicate decisions regarding an employee’s employment, including decisions to hire, terminate, promote, demote, transfer, suspend or discipline.
To communicate with employees regarding employment application related matters such as upcoming deadlines, action items, and other alerts and notifications.
To engage in corporate transactions requiring review or disclosure of employee records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the company.
To communicate with an employee’s family or other contacts in case of emergency or other necessary circumstance.
To provide Services to corporate customers who may request certain pieces of information about a company employee (such as name, phone number, and headshot) to permit the employee access or security clearance to their facility in advance of the company employee being dispatched to provide Services at the customer’s facility.
The company will retain each category of Personal Information in accordance with our data retention schedule. For more information please email [email protected].
We obtain the categories of personal information listed above from the following sources:
We may collect, use or disclose personal information about you for one or more of the following business and/or commercial purposes:
To provide the requested Services to you;
To take actions reasonably anticipated within the context of your employment application;
To provide you with useful content;
To ensure the proper functioning of our Services;
To offer and improve our Services;
To provide you with requested information or technical support;
To facilitate your movement through our websites or your use of our Services;
To do a better job of advertising and marketing our Services (subject to your consent where required by applicable law);
To advertise and market third party products and Services (subject to your consent where required by applicable law);
To diagnose problems with our servers or our Services;
In connection with our security and compliance programs;
To administer our websites;
To communicate with you;
To target current or prospective customers with our Services through online advertisements served on third-party sites by third-party vendors, such as Google (subject to your consent where required by applicable law); and
To assist us in offering you a personalized experience or otherwise tailor our Services to you.
In the previous 12 months, we have disclosed the categories of personal information we collect to the following third parties for the business purpose set out in the table below.
Identifiers: Service providers and vendors, partners, authorized users within your organization and other members
our corporate family.
Commercial Information: Service providers and vendors, partners, authorized users within your organization and
other members of our corporate family.
Internet/Network Information: Partners and other members of our corporate family.
Other Personal Information: Third party service providers, vendors and partners.
Inferences: Third party service providers and vendors, partners and other members of our corporate family.
When you interact with our websites, we may use, or authorize third-party partners and service providers to use, cookies, web beacons and similar technologies to improve your experience with us. These technologies can collect personal information about you that can be used by us and/or our authorized third-party partners and service providers. Using your personal information in this way may constitute a “sale” under the CCPA.
We do not “share” personal information with third parties for cross-context behavioral advertising.
Pursuant to the CCPA, in the preceding 12 months, we have sold the following categories of personal information for the purpose of showing you ads about Newfold’s Services:
Identifiers; and
Internet or other similar network activity
If you’d like to opt out of the sale of your personal information, please go to the site page of your account, or brand, and click on the Cookie Settings link in the footer of that page to update your Cookie Settings.
Except as provided above, we do not sell personal information to third parties.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. If you are using an authorized agent, please note that you will be required to verify your identity and provide written confirmation that you have authorized the agent to make a request on your behalf. For requests to access or delete, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
If you’d prefer a hard copy of this CA Privacy Notice or to access it as a PDF, this site permits you to print it to PDF or to a printer.
As a California resident, you may be able to exercise the following rights with respect to your personal information that we have collected, subject to certain exceptions:
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon our verification of your identity:
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. You may opt out here.
You have the right to non-discrimination for exercising these rights.
California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to a third party for the third party’s direct marketing purposes.
To exercise your California Consumer Rights, please submit a request to us by:
If you’d like to opt out of the sale of personal information, please go to the site page of your account, or brand, and click on the Cookie Settings link in the footer of that page to update your Cookie Settings.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. If you are using an authorized agent, please note that you will be required to verify your identity and provide written confirmation that you have authorized the agent to make a request on your behalf. For requests to access or delete, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
If you’d prefer a hard copy of this CA Privacy Notice or to access it as a PDF, this site permits you to print it to PDF or to a printer.
Newfold acts as a service provider to its customers. When acting in this capacity, we process personal information on behalf of our customer, and we have no direct relationship with the end-users who use our customers’ Services or products or visit our customers’ websites.
If you are an end-user of one of our customers whose personal information we process and you are seeking to exercise your rights under the CCPA, you should contact our customer directly.
