California Employee Privacy Notice

Last Modified: January 1, 2020

PURPOSE OF THIS NOTICE: This California Employee Privacy Notice (the “Notice”) describes Four Kites, Inc.’s (“Company,” “we,” “our” or “us”) collection and use of certain personal information relating to our current and former full-time, part-time and temporary employees and staff, as well as Company officers, directors and owners who are California residents (each an “Employee”).   This Notice describes our collection and use of personal information about Employees and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”).  We may provide Employees additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check and/or collect health information). 

SCOPE OF THIS NOTICE: This Notice applies to personal information that we collect and use in order to manage the employment relationship (including emergency contact information) and other personal information related to our administration of benefits to Employees.

What is personal information? In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.  

What isn’t covered by this notice?  This Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as protected health information (or “PHI”), consumer credit reports and background checks, publicly available data lawfully made available from state or federal governement records, or other information that is exempt under the CCPA.  This Notice also does not apply to the personal information we collect from contractors or job applicants, which are subject to separate notices.  

Are our practices the same for all Employees?  The categories of personal information we collect and our use of personal information may vary depending on the circumstances, such as an Employee’s role and responsibilities with Company. The information in this Notice is intended to provide an overall description of our collection and use of personal information about Employees.  

CATEGORIES OF PERSONAL INFORMATION COLLECTED: Generally, we may collect the below categories of personal information about Employees:

Name, Contact Info and other Identifiers. Identifiers such as 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.   
Protected Classifications. Characteristics of protected classifications under California or federal law such as race, color, sex, sexual orientation, gender identity, age, religion, national origin, disability, citizenship status, military/veteran status, marital status, medical condition, and pregnancy.
Usage Data (when using our network). Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any Company device, network or other information resource.
Employment History. Professional or employment-related information.
Education Information. Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Profiles and Inferences. Inferences drawn from any of the information identified above to create a profile about an Employee reflecting the Employee’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Other. Financial characteristics (account number, credit/debit card details, earnings), Personal characteristics (date of birth, place of birth), Economic and financial information (income, financial situation, tax situation, etc.), Physical data (height, weight, hair colour, eye colour, distinctive features), Lifestyle data (consumption of alcohol/tobacco, consumption of goods and services, information about travel, social contacts, etc.), Household composition (marital status and details, spouse/partner details, number of children, household/family members), Leisure activities and interest (hobbies, sports, other interests), Affiliations (charities, volunteering, clubs, but excluding  political or trade union affiliations); background checks (including criminal)

PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION: Generally, we may use the above categories of personal information for the following purposes:

Compensation and Benefits.  Relating to our administration of compensation and benefits, including:

  • Administering Employee payroll, salary and compensation
  • Administering any Employee benefits, including any employee pension or welfare benefit plans, (which may include the collection of personal information about others such as beneficiaries, where necessary to administer such benefits) 
  • Calculating withholdings or other lawful deductions, issuing tax return-related documents and forms to Employees
  • Reviewing timecards and reported time worked
  • Monitoring and managing PTO, holiday, FMLA, and other leaves of absences  
Management of Employment Relationship. To manage our relationship with Employees, including related to: 

    • Hiring, terminations, relocation, transfers, promotions and disciplinary actions  
    • Reviewing performance
    • Conducting Employee performance reviews, compensation and bonus reviews, and headcount and salary reviews
    • Administering and monitoring compliance with our policies and procedures 
    • Maintaining records of emergency contact information for use in the event of an emergency
    • Administering or performing employment contracts where applicable
    • Conducting pre-employment and employment screening (where relevant and pursuant to applicable laws)
    • Professional development and training purposes
    • Verification and management of applicable Employee credentials, licensing and other qualifications  
    • Facilitating Employee communication and collaboration, such as through the corporate directory and through Employee bios 
  • Supporting our equal opportunity employment policy and diversity and inclusion programs
Business Operations and Client Services. Relating to the organization and operation of our business and our performance of services to clients, including related to:

  • Operating our business by developing, producing, marketing, selling and providing goods and services
  • Providing after-sales services to clients 
  • Auditing and assessing performance of business operations, including client services and associated activities
  • Training and quality control  
  • Satisfying client reporting and auditing obligations
  • Facilitating business development opportunities, as relevant

Facilitating communications in furtherance of the foregoing

Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including: 

  • Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
  • Monitoring for, preventing, investigating, and responding to security and privacy incidents
  • Providing and managing access to physical and technical access controls
  • Monitoring activities, access and use to ensure the security and functioning of our systems and assets
  • Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring. Please see our handbook and our Acceptable Use Policy for additional information about our monitoring practices.
Auditing, Accounting and Corporate Governance. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions (e.g., mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions).  
Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance. 

CONTACTING US ABOUT THIS NOTICE:  If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact at privacy@fourkites.com.

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