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California Contractor Privacy Contractor Notice

Last Modified: January 1, 2020


PURPOSE OF THIS NOTICE: This California Contractor Privacy Notice (the “Contractor Notice”) describes Four Kites, Inc.’s (“Company,” “we,” “our” or “us”) collection and use of certain personal information relating to our current and former contractors and other non-employee service providers or vendors who are California residents (each a “Contractor”).  This Contractor Notice describes our collection and use of certain personal information about Contractors and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”).  We may provide Contractors 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 Contractor Notice applies to personal information that we collect and use in order to manage work assignments or projects and our relationship with Contractors.

What is personal information? In this Contractor 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 Contractor 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 Contractor Notice also does not apply to the personal information we collect from employees or job applicants, which is subject to a separate notice.

Are our practices the same for all Contractors?  The categories of personal information we collect and our use of personal information may vary depending on the circumstances, such as a Contractor’s work assignment or project or the amount or sensitivity of the information or assets they may access as part of their work assignment or project. The information in this Contractor Notice is intended to provide an overall description of our collection and use of personal information about Contractors.

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

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.
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).

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

Administering Contractor Relationship. To administer Contractor projects or assignments and Company’s relationship with Contractors, including:

    • Reviewing, assessing and administering payments to or for Contractors
    • Reviewing reported time worked, if applicable
    • Reviewing and validating qualifications (e.g., credentials and licenses) and experience and approving assignments or projects
    • Conducting due diligence and screening of Contractors
    • Monitoring compliance with agreements and Company policies and procedures, if applicable
    • Maintaining records of emergency contact information for use in the event of an emergency
    • Granting access to relevant systems and assets
  • Otherwise as necessary related to a particular project or assignment
General Business Operations. In support of our business operations, including related to:

    • Auditing and assessing performance of business operations, including client services and associated activities
    • Quality control
  • Satisfying client reporting and auditing obligations
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 agreements, policies or procedures
  • 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 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 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 regulationssocial security and tax lawsenvironmental 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 Contractor Notice, please contact [email protected].