California Addendum: California Employee Privacy Policy

Last Updated:  December 4, 2024

In order to facilitate your employment, Omnidian Inc. (“Omnidian”) collects and processes certain categories of “personal information” from and about you.  “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Categories of Personal Information:

For the purposes of this California Employee Privacy Policy, Omnidian collects, and has collected in the preceding 12 months, the following categories of Personal Information from and about you:

  • Application and Recruitment Information
    • Data you provide to Omnidian during the application process;
    • Data about your credit history, criminal records or other data revealed during background screenings as permitted by applicable law;
    • Data generated by interviewers and recruiters, based on their interactions with you or information publicly available about you on the Internet; 
    • Your offer letter or contract of employment and any amendments to it;
    • Data provided by third-party placement firms, sourcers, recruiters, or job-search websites, where applicable;
    • Recommendations or references provided on your behalf by others; and
    • Data from third-party sites that you authorize to provide us information, such as LinkedIn or Indeed;
  • Core Employment Information
    • Your personal details, meaning your name, contact information, such as your postal or residential address, email address, and telephone number, your IP address, your emergency contact information, employment and educational history, other records of professional achievement (including your resume, CV, and other application materials), and biographical information;
    • Social Security number, driver’s license, state identification card or passport number, signature, physical characteristics (e.g., through a photograph, or video camera);
    • Correspondence Omnidian sends or receives from you as well as correspondence you send or receive on Omnidian’s behalf;
    • Information needed to pay you your wages and reimburse you for business expenses;
    • Information needed to provide employment-related benefits;
    • Records relating to your employment performance and history (for example, training records, performance appraisals, other performance measures, and disciplinary and grievance records);
    • Attendance records; 
    • Geolocation data (physical location or movement); 
    • Audio, electronic, visual, thermal, olfactory, or similar information;
    • Usage data regarding your usage of Omnidian’s information systems for purposes of data security, system performance monitoring, and system improvement.
    • Inferences drawn from your other personal information 
  • Legal Compliance Information
    • Information needed for monitoring Omnidian’s compliance with our equal opportunities obligations, such as race, national origin, sex, sexual orientation, age, and veteran status; 
    • Documentation required under immigration laws, such as citizenship, and visa or permanent resident status;
    • When permitted or required by applicable law, data about your health or disability where (1) it relates to your ability or availability to work or to a workplace accommodation; (2) is needed to comply with Omnidian’s legal obligations about the health and safety of the workplace; or (3) is needed to administer sick pay or other benefits; and
    • Where permitted by applicable law, data about race, ethnicity, religion, disability, gender, sexual orientation, and other legally protected or significant characteristics or statuses, for purposes of government reporting where required, as well as to understand the diversity characteristics of Omnidian’s workforce.

Purposes of Collection:

The purposes for which Omnidian uses your Personal Information are as follows:

  • Performance in the employment relationship between you and Omnidian;
  • The legitimate legal interest of Omnidian including rewarding talent, enabling a dynamic workforce, staffing appropriately for Omnidian, ensuring proper communication within Omnidian, ensuring that employees carry out business functions, and providing tools to employees for further business purposes; or
  • The compliance with a legal obligation to which Omnidian is subject.

Additional Disclosures: 

We may disclose Personal Information in certain circumstances, including to: comply with our legal obligations; to protect the rights and property of our customers and the public; to detect and respond to suspected illegal activities and threats to the health and safety of any person or of our systems or services; in connection with, or during negotiations of, any merger, joint venture, sale of Omnidian assets, financing, or acquisition of all or a portion of the Omnidian business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings); to maintain Omnidian’s business operations, including, for example, by providing or enabling our service providers, professional advisors, or other similar entities to assist with the administration of payroll, pension, benefits, performance management, training, communication platforms, and expense management and facilitate internal programs relating to diversity, inclusion, and anti-discrimination; and with your consent and at your direction. 

In the preceding twelve (12) months, Omnidian has disclosed personal information to the following categories of recipients: 

Personal Information Category Category of Recipients

Identifiers

Recruitment and personnel management service providers, benefits providers, payroll providers, fraud detection and security service providers

Protected classification characteristics under California or federal law.

Recruitment and personnel management service providers and benefits providers

Commercial information

Recruitment and personnel management service providers and payroll providers

Internet or other similar network activity

Fraud detection and security service providers

Geolocation data

Fraud detection and security service providers

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

Recruitment and personnel management service providers, fraud detection and security service providers

Professional or employment-related information.

Recruitment and personnel management service providers, fraud detection and security service providers

Inferences drawn from other personal information.

Recruitment and personnel management service providers

Sensitive personal information

Recruitment and personnel management service providers, benefits providers, payroll providers, government authorities, regulators

We do not use or disclose your sensitive personal information for purposes other than those permitted by California law. 

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you. We process, maintain, and use this information only in a de-identified fashion and will not attempt to re-identify such information except as permitted by law. 

Retention of Your Personal Information:

When you are given and accept an offer of employment by Omnidian, Personal Information collected during your pre-employment period becomes part of Omnidian  personnel records for you, to be retained throughout and for a period after your employment with Omnidian. 

Omnidian determines the retention period of your information based on the following retention criteria:

  • Omnidian retains your personal data as long as it has an ongoing relationship with you;
  • Omnidian retains your personal data where it is required to do so by a legal obligation to which it is subject; and
  • Omnidian retains your personal data where this is advisable to safeguard or improve Omnidian’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).

Selling and Sharing of Your Personal Information:

Omnidian has not and does not sell or share your Personal Information.

Your Rights and Choices:

You have specific rights regarding your Personal Information. This section describes and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal and sensitive information, unless responding to the request is impossible or involves a disproportionate effort. Once we receive and confirm your verifiable request, we will disclose to you:

  • The categories of personal information and sensitive information we collected about you.
  • The categories of sources for the personal and sensitive information we collected about you.
  • Our business or commercial purpose for collecting, using and/or disclosing that information.
  • The categories of third parties, contractors and service providers, if any, with whom we share, sell or disclose that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, a list of those disclosures, identifying the personal information categories that each category of recipient obtained.
  • Whether your information is sold or shared.
  • The retention period or criteria used for retention.

You also, through a verifiable request, have the right to have your personal information transmitted directly from us to a third party, where technically feasible. 

Correction and Deletion Request Rights

You have the right to request that we correct or delete any of your personal information that Omnidian collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will correct or delete (and direct any service providers to correct or delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Fully and adequately perform in the employment relationship between you and Omnidian;
  • Take actions reasonably anticipated within the context of our ongoing employment relationship with you, or otherwise perform our employment contract with you;
  • Help to ensure security and integrity, to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; and
  • Comply with any and all legal obligations.

Exercising Access, Data Portability, and Correction and Deletion Rights

To exercise the access, data portability, correction, and deletion rights described above, please complete a request form located at:

https://www.omnidian.com/your-privacy-choices/

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child.

You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

  • Provide enough 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. We will only use personal information provided in a verifiable request to confirm the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. 

Unless otherwise requested, the disclosure shall cover the 12-month period preceding our receipt of the verifiable consumer request and shall be made in writing and delivered through your account with us, or by mail or electronically.

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, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable 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.

Non-Discrimination

We will not discriminate against you for exercising any of your rights described above. Unless permitted by law, we will not:

  • Deny you services.
  • Provide you a different level of service.
  • Discriminate in making employment decisions.

Shine the Light Disclosure

We have not shared any personal information with other companies for their direct marketing use within the immediately preceding calendar year. Accordingly, California’s “Shine the Light” law, Cal. Civil Code § 1798.83 to § 1798.84, does not apply to us and we have not established any mechanism for you to request information on our sharing of information for third parties’ marketing purposes.

Changes To Employee Privacy Policy

Omnidian may make changes to this Employee Privacy Policy, by updating this Policy or providing you with an addendum to this Policy. You should review this California Employee Privacy Policy periodically to keep up to date on our most current policies and practices concerning your personal information.

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