Notice at Collection

     

    TO CALIFORNIA CONSUMERS, EMPLOYEES, OFFICERS, DIRECTORS, CONTRACTORS, AND APPLICANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION

    Effective Date:  8/8/2023

    FI Connect, its parent company Origence and its affiliates, (the “Company” or “we”) are committed to protecting the privacy and security of the personal information of consumers, current and former employees, Officers, (“Employees”), contractors (together with Employees, “Personnel”), their emergency contacts and beneficiaries, directors and job applicants who reside in the State of California. The Company does not sell or otherwise disclose this personal information, including sensitive personal information, for monetary or other consideration to any third parties.

    The Company is committed to complying with the California Consumer Privacy Act (“CCPA”), and all data privacy laws in the jurisdictions in which the Company collects personal information, including sensitive personal information, of personnel, directors, and job applicants.

    What Categories of Personal Information Do We Collect and How Do We Use This Information?

    We collect the following categories of personal information for the purposes described below:
    Category of Personal DataPersonal Information CollectedPurpose
    Personal identifiers

    Examples:

    • Real name
    • Preferred name
    • Postal address
    • Email address
    • Unique personal or online identifier
    • Internet Protocol address
    • Social Security number
    • Passport number, driver’s license, or state identification card number
    • Date of birth
    • Other similar identifiers

    The Company collects personal information to process job and board of director applications; send correspondence and invitations to board of directors and spouses; onboard Personnel; enroll and administer benefits; enter contracts; and use for general human resource purposes.

    The Company uses some personal identifiers for cybersecurity monitoring purposes and are key in security incident event monitoring response.

    Records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))

    Examples:

    • Name
    • Signature
    • Social Security number
    • Address
    • Telephone number
    • Passport number, driver’s license or state identification card number
    • Insurance policy number
    • Education
    • Employment history
    • Bank account number
    • Credit card information or any other financial information
    • Medical information or health insurance
    		The Company collects this information to process job and board of director applications; onboard Personnel; send correspondence and invitations to board of directors and spouses; enroll and administer benefits; enter into contracts; and use for general human resource purposes.

    The Company may collect pay information – such as payroll deduction information, banking information for direct deposit, for expense reimbursement, to pay its Personnel and comply with applicable laws.
    Category of Personal DataPersonal Information CollectedPurpose
    Protected classification characteristics under state or federal law

    Examples:

    • Race
    • Religious creed
    • National origin
    • Ancestry
    • Physical or mental disability
    • Medical condition
    • Marital status
    • Sex, gender, gender identity, or gender expression
    • Age
    • Sexual orientation
    • Military and veteran status

    The Company may collect equality and diversity information, such as minority, veteran and disability status, through voluntary self-disclosure and other means to implement the Company’s diversity programs and to comply with applicable laws.

    The Company may collect health and safety information to maintain a safe workplace; assess your working capacity; administer health and Workers’ Compensation insurance programs; and comply with applicable laws.

    The Company may also collect information necessary for benefits enrollment and administration purposes.

    Commercial information

    Examples:

    • Records of personal property, products or services purchased, obtained, or considered
    • Other purchasing or consuming histories or tendencies
    		If you are a contractor, we may collect commercial information from or about you in connection with obtaining services from you.

    Category of Personal Data

    Personal Information Collected

    Purpose

    Internet or other similar network activity information

    Examples:

    • Email, computer, internet, telephone, and mobile device usage
    • IP address, log-in information, and location information
    • Browsing history, search history, or information regarding your interaction with a website, application or advertisement

    The Company may collect this information to protect Company, customer, and Personnel property, equipment and confidential information; monitor Personnel performance; and enforce the Company’s electronic communications acceptable use policies. Information may also be used for cybersecurity monitoring purposes which are key in security incident event monitoring response.

    Geolocation data

    Examples:

    • Physical location or movements

    The Company may collect geolocation data for general human resource purposes and for cybersecurity monitoring purposes which are key in security incident event monitoring response.

    Professional or employment-related information
    • Performance management information, such as employment status (full-time or part-time, regular or temporary), work schedule, job assignments, hours worked, accomplishments and awards
    • Training and development information
    • Performance evaluation information
    • Discipline and counselling information
    • Employment termination information

    The Company may collect professional and employment- related information to manage its relationship with Personnel.

    Personal Data about children under the age of 16

    Personal information about Employees’ dependents under the age of 16.

    The Company may collect information about Employees’ dependents under the age of 16 if Employees voluntarily provide such information in connection with the enrollment and administration of benefits and other human resource purposes that involve such dependents.

    Category of Personal Data

    Personal Information Collected

    Purpose

    Legal and Contractual Information

    Information necessary to: respond to law enforcement and governmental agency requests; comply with legal obligations; exercise legal rights; and initiate or respond to legal claims

    The Company may collect this information to comply with legal requirements and to establish, exercise, and defend legal rights and claims.

    Emergency Contact Information
    • Name and contact information
    • Relationship to Employee

    The Company may collect this information to contact the Employee’s designated emergency contact persons in the event of an emergency.

    Beneficiary Information
    • Name and contact information
    • Relationship to the Employee
    • Birth date
    • Social Security Number
    • Information necessary to process benefits claims

    The Company may collect this information to enroll and administer benefits programs for beneficiaries of Employees.

    Sources of Personal Information

    The Company does not engage in the selling or sharing of consumers’ personal information, as defined under the CCPA.

    Retention of Personal Information

    The length of time the Company will retain each category of personal information will depend on a number of criteria including the length of time we are required to maintain the personal information in order to comply with applicable regulatory requirements and the length of time the information is needed to accomplish the business or commercial purposes for which the information is collected, used, or disclosed.

    CONTACT FOR QUESTIONS

    If you have any questions or concerns regarding this Notice or the collection of your personal information, please contact us through our parent company, Origence at [email protected].

    Individuals with disabilities may access this notice in an alternative format by contacting the Compliance department at [email protected].

    Rev. 8/8/2023