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CCPA Privacy Policy

The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

Right to Know

Applicants, employees, and independent contractors residing in California have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.


The information below reflects the categories of personal information we have collected during the past twelve months from applicants, employees, and independent contractors who are California residents. Please click on each category below to view the sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom we disclosed that information, and our anticipated retention period for each category of information.


Personal Information Category/Sensitive Personal Information Category¹

(e.g., name, mailing address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license or passport number, or other similar identifiers)


Source(s) of Personal Information Collection


Directly from you; indirectly from you as you navigate or use our systems.

For job applicants: Third-party search firms; background check administrators.

Business/Commercial Purpose for Collection

Meet our legal obligations; perform human resource management; communicate with you; administer payroll and benefits; protect and secure our workforce and environment.

For job applicants: Assess your qualifications for jobs; communicate with you.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Human resources service providers.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.

(e.g., name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information)

Source(s) of Personal Information Collection

Directly from you; indirectly from you as you navigate or use our systems.

For job applicants: Third-party search firms.

Business/Commercial Purpose for Collection

Meet our legal obligations; perform human resource management; communicate with you; administer payroll and benefits; protect and secure our workforce and environment.

For job applicants: Assess your qualifications for positions with Protective; communicate with you.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Human resources service providers.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
(e.g., race, ethnicity, gender, age, marital status, veteran or military status)

Source(s) of Personal Information Collection

Directly from you.

For job applicants: Third-party search firms; background check administrators.

Business/Commercial Purpose for Collection

Meet our legal obligations; support diversity, equity & inclusion (DE&I) initiatives.

Note: This information will not be used to impact any terms or conditions of job application, employment or contractor services.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Human resources service providers.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
(e.g., browsing history, search history, and information about individual interactions with Protective’s proprietary systems)

Source(s) of Personal Information Collection

For employees and independent contractors using Company managed systems: Indirectly from you as you navigate or use our systems; internet service providers.

For all others: We do not collect.

Business/Commercial Purpose for Collection

Perform human resource management; protect and secure our workforce and environment.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Not applicable.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
(e.g., education history, employment history, professional licenses)

Source(s) of Personal Information Collection

Directly from you.

For job applicants: Third-party search firms; background check administrators.

Business/Commercial Purpose for Collection

Perform human resource management; protect and secure our workforce and environment.

For job applicants: Assess your qualification for position with Protective.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Human resources service providers.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
(e.g., audio, electronic, visual, thermal, olfactory, or similar information)

Source(s) of Personal Information Collection

For employees and contractors using Company managed systems: Directly from you; devices you use to access our systems.

Business/Commercial Purpose for Collection

Perform human resource management; protect and secure our workforce and environment.

For job applicants: Assess your qualification for position with Protective.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Human resources service providers; technology service providers.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
(e.g., user names, account numbers, or card numbers combined with required access code, security code or password to access an account)

Source(s) of Personal Information Collection

For employees and contractors using Company managed systems: Directly from you; technology service providers.

Business/Commercial Purpose for Collection

Protect and secure our workforce and environment; perform human resource management.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Technology service providers; human resources service providers

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
Source(s) of Personal Information Collection

For employees and contractors using Company managed systems: Directly from you; indirectly from you when you use our systems.

Business/Commercial Purpose for Collection

Protect and secure our workforce and environment.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Not applicable.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.
(e.g., daily device steps for administration of wellness benefits, health insurance information.)

Source(s) of Personal Information Collection

For employees: Directly from you; human resources service providers.

Business/Commercial Purpose for Collection

Protect and secure our workforce and environment; management of employee benefit rewards.

Third Parties, Service Providers, and Contractors Receiving Personal Information

Human resources service providers.

Retention Period

This category of information is subject to our internal policies on retaining applicant, employee, or independent contractor information. These policies are based on applicable legal retention requirements for retaining personal information of applicants, employees, or independent contractors. As part of our internal policies, we have a process in place to determine when business records are no longer needed and can be disposed of in a secure manner.

We do not collect or process sensitive personal information for the purpose of inferring characteristics about you. We also do not disclose sensitive personal information for purposes other than those specified in the CCPA regulations. Therefore, we do not offer the option to limit the use of sensitive personal information.

We do not sell the personal information or sensitive personal information we collect from our applicants, employees, and independent contractors. We also do not share applicant, employee, or independent contractor personal information or sensitive personal information with third parties for cross-context behavioral advertising.

We have no actual knowledge of selling or sharing the personal information or the sensitive personal information of minors under 16 years of age.

 

Right to Delete Personal Information

 

You have the right to request the deletion of your personal information, subject to certain exceptions.

 

Right to Correct Inaccurate Personal Information

 

You have the right to request the correction of any inaccurate personal information that we maintain about you.

 

Right to Access

 

You have the right to request the categories and specific pieces of personal information we have collected about you.

 

Right of Non-Retaliation and Non-Discrimination

 

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. The Company does not retaliate or discriminate against you for exercising the privacy rights conferred to you under the CCPA.

 

Exercising Your Rights

 

To exercise your rights, you may contact us via phone at 1-844-908-1164 or via email at CCPA.Inquiry@protective.com. Requesters will need to provide us with personal information in order to verify their identity and residency, including name, email, and state of residence. We will compare the information you provide with our internal records. The personal information that we use to verify identity and residency will not be used for any other purpose.

You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. The Company may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.

An authorized agent shall not use a consumer’s personal information, or any information collected from or about the consumer, for any purposes other than to fulfill the consumer’s requests, verification, or fraud prevention.

 

Contact Information

If you have questions or concerns about our privacy practices, contact us at: CCPA.Inquiry@protective.com

Last Updated: January 1, 2023

[1] “Personal Information” and “Sensitive Personal Information” categories are fully defined in the CCPA (Cal. Civ. Code § 1798.140). (Cal. Civ. Code)

WEB.4559763.02.23