Effective Date: July 22, 2022
Last Updated on: July 22, 2022
Information We CollectWe and our Sites collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- 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;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
|A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|A name, signature, Social Security number, 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.
Some personal information included in this category may overlap with other categories.
|C. Protected classification 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 (including familial genetic information).
|D. Commercial information.
|Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. 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.
|F. Internet or other similar network activity.
|Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
|G. Geolocation data.
|Physical location or movements.
|H. Sensory data.
|Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.
|Current or past job history or performance evaluations.
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. 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.
|K. Inferences drawn from other personal information.
|Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|L. Sensitive Personal Information.
|Sensitive personal information” means: (1) personal information that reveals (A) a consumer’s social security, driver’s license, state identification card, or passport number; (B) a consumer’s 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; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mall, email and text messages, unless the business is the intended recipient of the communication; (F) a consumer’s genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying a consumer; (B) personal information collected and analyzed concerning a consumer’s health; or (C) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
We and our Site obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase, or when you register on our site or provide information to us.
- Indirectly from you. For example, from observing your actions on our Site.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information, such as, if you share your name and contact information to allow Recruiters to view your materials.
- To provide, support, personalize, and develop our Site, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA or CPRA.
- To evaluate or conduct 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 Site users is among the assets 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 may share your personal information by disclosing it to a third party for a business purpose. We only 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 and/or in the future, Company has disclosed or may disclose personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell personal information. In the preceding twelve (12) months and/or in the future, Company has not sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
|Category of Third-Party Recipients
|Business Purpose Disclosures
|B: California Customer Records personal information categories.
|C: Protected classification characteristics under California or federal law.
|D: Commercial information.
|E: Biometric information.
|F: Internet or other similar network activity.
|G: Geolocation data.
|H: Sensory data.
|I: Professional or employment-related information.
|J: Non-public education information.
|K: Inferences drawn from other personal information.
Reselling Personal Information
The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. The following businesses purchase personal information from us and may resell that information. To opt-out of those sales, please send us an email stating your request to [email protected].
- None at this time
Deidentified Patient Information
We do not sell and/or disclose deidentified patient information exempt from the CCPA to third parties.
Your Rights and Choices
The CCPA and/or CPRA provides consumers (California residents) 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 (see Exercising Your Rights to Know, Delete or Correct), 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.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If personal information was shared for cross-context behavioral advertising.
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, Delete or Correct), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Correct
You have a right to correct data that we hold about you that is inaccurate.
Right to Limit Use of Sensitive Personal Information
You have the right to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services as well as other specified legitimate business purposes. “Sensitive personal information” is defined above. Any of the above information that is already publicly available is not considered to be sensitive personal information.
Exercising Your Rights to Know, Delete or Correct
To exercise your rights to know, correct or delete described above, please submit a request by either:
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may also make a request to know, correct or delete on behalf of your child by sending us an email stating your request to [email protected].
You may only submit a request to know twice within a 12-month period. Your request to know, correct 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
- 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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
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, sharing and sensitive personal information use opt-out or opt-in rights, see Personal Information Sales or Sharing Opt-Out and Opt-In Rights and Limitation of Use of Sensitive Personal Information 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-day timeframe, send us an email stating your request to [email protected].
We endeavor to substantively respond to a verifiable consumer 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.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
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 consumer 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 and Sharing Opt-Out and Opt-In Rights and Limitation of Use of Sensitive Personal Information Rights
If you are age 16 or older, you have the right to direct us to not sell or share your personal information or limit the use of your sensitive personal information at any time (the “right to opt-out”). We do not sell or share the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales or sharing may opt-out of future sales at any time.
To exercise the right to opt-out or limit the use of your sensitive personal information, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
- Emailing your request to [email protected] with the Subject of either of the following:
- “Do Not Sell or Share My Personal Information”
- “Limit the Use of My Sensitive Personal Information”
Once you make a request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. However, you may change your mind and opt back in to personal information sales or sharing or additional uses of your sensitive personal information at any time by:
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.
We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA and CPRA that can result in different prices, rates, or quality levels. Any 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. We currently provide the following financial incentives:
- None at this 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 [email protected] or write us at: 15225 Alton Parkway, Suite 100, Irvine, CA 92618.
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 Policy in an alternative format due to having a disability, please contact [email protected].