California Employee Privacy Notice

 

1. Purpose

This California Employee Privacy Notice outlines how Stance Health Solutions, Inc., on behalf of itself and its subsidiaries (collectively “Stance” or “We”), collects, uses, shares, and protects the personal information of our current and former employees, contractors, and job applicants. We are committed to ensuring transparency and protecting your privacy in accordance with applicable federal and California state laws, including the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”).

 

2. Scope

This notice applies to all Personal Information collected from individuals residing in the State of California who are considered “Consumers,” as defined in the CCPA, including our current and former employees, contractors, and those who engage with our recruiting and hiring process, including but not limited to:

· Visitors to our careers website

· Applicants submitting job applications

· Individuals participating in interviews or assessments

· Users of our interview self-scheduling tools

This notice covers all Personal Information collected directly from you including through public-facing hiring platforms, including our careers landing page, job application pages, and interview scheduling systems, and all Personal Information collected from other sources, including recruiters, prior employers, professional references you provide to us, educational institutions, pre-employment screening services, credentialing and licensing organizations, and publicly available sources such as your social media profile.

 

3. Policy

We may collect, use, and retain certain Personal Information collected from or about you solely for legitimate business and legal purposes, as described more fully below. Types of Personal Information We may collect include:

 

Personal Information Category

 

Personal Identifiers

A real name, alias, postal address, telephone number, mobile device ID, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, age or date of birth.

 

Administrative employment purposes*

 

Records Identified by State law (including Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information.

 

Administrative employment purposes*

 

Protected classified characteristics under California or federal law

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, veteran or military status, genetic information [CAD1] (including familial genetic information).

 

Administrative employment purposes*

Implementation of Stance’s diversity programs and to comply with applicable laws

 

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

If you are a contractor, Stance may collect commercial information about you or in connection with obtaining services from you

 

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

 

Administrative employment purposes*

 

Internet or other electronic network activity information

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

 

Protection of Stance property, equipment, and confidential information

Enforcement of Stance’s electronic communications acceptable use policies

 

Geolocation Data [CAD2] 

Physical location or movements.

 

Administrative employment purposes*

 

Sensory data

Audio, electronic, visual, thermal, olfactory or similar information, including photographs 

 

Stance may collect audio and visual information of personnel for identification purposes

Stance may use audio and visual information of personnel to promote the company

Stance may collect audio and video recordings of training sessions

 

Professional or employment-related information

Current or past job history or performance evaluations.

 

Administrative employment purposes*

 

Non-public education information (per the Family Educational Rights and Privacy Act (20 USC § 1232g, 34 CFR Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

 

Administrative employment purposes*

 

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Administrative employment purposes*

 

Personal Information about children under the age of 16

Personal Information about employees’ dependents under the age of 16

 

Enrollment and administration of benefits and other human resources purposes that involve such dependents

 

Legal and contractual information

Information necessary to respond to law enforcement and government agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to legal claims

 

Compliance with legal and contractual requirements

Establishing, exercising and defending legal and contractual rights and claims

 

Emergency Contact Information

Name and contact information, and relationship to employee

 

Contacting the employee’s designated emergency contact person(s) in the event of an emergency

 

Beneficiary Information

Name and contact information, relationship to the employee, date of birth, social security number, and other information necessary to process benefits claims

 

Enrollment and administration of benefits programs for employees’ beneficiaries

*Administrative employment purposes may include the following purposes:

· Onboarding employees

· Enrolling and administering employment benefits

· Entering into contracts

· Administration of Workers’ Compensation insurance programs

· General human resource purposes

· To assess qualifications for current and future job openings and/or promotions

· To communicate regarding the status of your application

· To schedule interviews and assessments

· To conduct background checks

· To comply with applicable laws and regulatory requirements

· To improve our hiring practices and platforms

 

We do not sell or share applicant personal information with third parties for monetary consideration. We may share information as necessary for the purposes described in this notice under strict contractual obligations consistent with applicable laws. This may include:

 

· Our affiliates

· Service providers (e.g., hosting, technology and communications providers, security and fraud prevention consultants, analytics providers, background and reference check screening services, and hiring process and benefits management and administration tools)

· Government authorities and law enforcement, in response to lawful requests by public authorities

· Business transfers (if Stance undergoes a merger, acquisition, bankruptcy or other transaction in which that third party assumes control (in whole or in part) of our business

· Professional advisors (e.g., legal and accounting resources and consultants)

 

Data Retention. We retain applicant data only for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, and defend against potential claims. Once it is no longer useful for the business purpose, it is either anonymized or deleted.

 

4. Procedure

 

Notice and Consent. If you are applying for employment with Stance, be advised that by submitting your application, you acknowledge and consent to the collection and use of your personal information as described in this policy. Where required by law, we will obtain explicit consent before collecting sensitive information.

 

Access and Rights (California Residents). If you are a California resident, you may have the following rights under the CCPA and CPRA:

· You may request disclosure of the categories and specific pieces of Personal Information We have collected about you.

· You may request the specific pieces of Personal Information We have collected about you. 

· You may request the categories of sources from which We have collected your Personal Information.

· You may request the business or commercial purpose(s) for collecting and disclosing your Personal Information. 

· You may request a copy of your Personal Information retained by Stance

· You may request the categories of third parties with whom We share your Personal Information 

· You may request deletion of your personal information, subject to certain exceptions.

· You may request correction or update of inaccurate personal data.

· You may request to limit the use and disclosure of sensitive information 

· You will not receive discriminatory treatment for exercising any of your privacy rights.

To exercise your rights, please contact us at PeopleTeam@stancehealthsolutions.com

 

Security Measures. We implement reasonable administrative, technical, and physical safeguards to protect personal information against unauthorized access, loss, or misuse.

 

Contact Information. If you have questions about this Privacy Policy or your personal information, please contact:

PeopleTeam@stancehealthsolutions.com